For several years now, the independent testing—or auditing—of BSA/AML compliance programs (The “Fourth Pillar”) has been cited as one of the most common deficiencies found in bank BSA examinations. Inadequate audits prompt examiners to question management’s judgment in failing to assess and manage risk effectively, as repeatedly reflected in examination findings and harsher enforcement actions, and further providing examiners with reasons to dig deeper during a scheduled BSA examination.

This session will cover issues such as:
• Core requirements versus current regulatory expectations;
• Differences between compliance reviews and BSA audits;
• The ingredients of a successfully performed audit;
• Applying the risk-based approach and scoping the audit;
• Dealing with unforeseen issues;
• Regulators' concerns over auditor competency;
• Examiners' reliance on audit reports;
• Auditors' and examiners' pet peeves;
• Reporting to management and the Audit Committee;
• Ongoing tracking of audit findings and corrective actions.