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What Bankers Can Do To Help

T his section highlights fundamental controls that are important for effective anti-money laundering systems and legal compliance. These controls include effective BSA compliance and customer due diligence programs, compliance with Office of Foreign Assets Control (OFAC) guidelines, suspicious activity monitoring and reporting systems, and risk-based anti-money laundering programs.

Establish Effective BSA Compliance Programs

Banks must have a BSA compliance program. National banks, as outlined in 12 CFR 21.21, must develop, administer, and maintain a program that ensures and monitors compliance with the BSA, including record keeping and reporting requirements. A bank’s compliance program must be written, approved by the board of directors, and noted as such in the board meeting minutes. The program must also contain:

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"If you place one seed of truth on a particular side of the cosmic scale, it can sway the entire balance of power in a new direction". - Dr. Jur. George Mentz Editor of the Magazine of Wall Street Est. 1907 www.magazineofwallstreet.com

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