BSA/AML/OFAC Compliance Programs

BSA/AML/OFAC Compliance Programs

Whether you are a traditional bank or a non-traditional Money Services Business, compliance with the anti-money laundering (AML) requirements under the Bank Secrecy Act (BSA) is an unavoidable component of conducting your operations. Many companies are also required to meet the Office of Foreign Assets Control (OFAC) compliance obligations. It is essential to have a well-developed BSA/AML/OFAC compliance program in place that manages compliance risks and promotes best practices for your industry. 

The U.S. Department of Treasury’s Financial Crimes Enforcement Network’s (FinCEN) changes its guidance on BSA/AML compliance on a regular basis, and it can be challenging to manage a program in full compliance with changing rules, as well as OFAC economic sanctions obligations and applicable state regulations. At Bates Group LLC, our specialists understand and identify all requirements for different types of financial businesses, and our goal is to help you achieve full compliance and maximize profitability. 

Our team’s focus is on helping banks and Money Services Businesses develop, analyze, and improve their compliance programs, as well as enhance and review their existing programs. Please contact us directly today for a consultation with a compliance expert at Bates Group LLC.

Program Development

Designing and implementing a comprehensive and effective BSA/AML/OFAC compliance program is no simple task. Programs will vary based on each specific company, though the following are major components of nearly every compliance program.  

• Risk Assessment – Each company has a different risk profile, so there is no one-size-fits-all approach to compliance programs. FinCEN expects each institution to tailor its program specifically to its operations, and our specialists can assess your risks based on your location, customers, and services, and then develop a compliance program based on each individual risk profile. 
• Policies and Procedures – Each program should have clear policies and procedures for every role in the business and each type of transaction. Policies should clearly communicate internal responsibilities, systems, and best practices. 
• Independent Review – A key part of AML compliance is conducting Independent Reviews to test your program for risk or compliance issues. Review frequency and scope will vary based on your operations, and we can advise on necessary reviews as well as conduct the reviews. 
• Compliance Training – Everyone in your company who participates in the BSA/AML/OFAC compliance program should understand relevant parts of the program and their responsibilities. Training should be conducted on a regular basis to maintain a culture of compliance.

Program Enhancement 

If you have an existing compliance program that you need to be updated based on new operations or the ever-changing regulatory environment, our team can review and enhance your existing policies and procedures. We regularly work with clients on gap analysis’ and update programs as necessary to minimize compliance risk in the future. 

Discuss How Our Experts Can Help with Your BSA/AML/OFAC Compliance Programs 

When your bank or Money Services Business needs assistance with BSA/AML/OFAC compliance programs or reviews, you can trust the experts at Bates Group LLC. For a consultation about our services, please contact us directly.