The expectation for enhanced due diligence did not change with the passing of the 5th BSA pillar. However, examiner expectations for enhanced due diligence (EDD) continue to evolve because it is a critical component of your bank’s BSA Program. TCA® first addressed the EDD topic in a 2015 In Depth article. The November 2018 BAT […]
What do CDD and EDD Mean? Part II: Enhanced Due Diligence Read More »
What is all the buzz about customer due diligence (CDD) and enhanced due diligence (EDD)? The expectations for CDD and EDD did not change with the addition of the 5th BSA pillar. The expected due diligence requirements were simply codified. TCA® first addressed this topic in depth in a 2015 article. What does that mean
What do CDD and EDD Mean? Part I: Customer Due Diligence Read More »
When your institution is examined for compliance with any law or regulation, the measure of your efforts will be based on your ability to self-identify and self-correct any deficiencies. Ongoing monitoring of key processes helps to ensure that any errors or warning flags are identified early. Monitoring is a required element of a compliance management
Quality Assurance Monitoring for BSA/AML Compliance Programs Read More »
The regulators are upping their game and are becoming more familiar with Automated Monitoring Systems. They are starting to push the boundaries of a model validation and their expectations for a “complete” model testing review. Some examiners are more advanced than others, but the word is being spread and soon they’ll all catch on! This
Model Validations—Why Do I Need a GAP Analysis? Read More »
April showers brought May flowers, or in the BSA world, beneficial ownership is finally here. The BAT has been fielding questions left and right about some of the nuances of the new CDD requirements. The BAT has speculated on the implications of CDD as the fifth pillar for years now and one thing is clear:
Beneficial Ownership and Lending: Have we considered all possibilities? Read More »
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