FinCEN and Treasury on Bank Secrecy Act and Anti-Money Laundering Awareness

Recent guidance from the U.S. Department of the Treasury and the Financial Crimes Enforcement Network (FinCEN) reinforces the continued regulatory focus on Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) compliance.

FinCEN latest advisory highlights risks associated with payroll tax evasion schemes, shell companies, funnel accounts, and unrecorded wage payments. The press release also identifies potential indicators associated with labor trafficking and outlines red flags financial institutions should consider when performing customer due diligence, monitoring transactions, and filing Suspicious Activity Reports (SARs).

These developments serve as a reminder that financial institutions should regularly evaluate their BSA/AML programs to ensure they remain effective, risk-focused, and aligned with evolving regulatory expectations.

Are Your BSA and AML Programs Effective?

Independent testing remains a key component of an effective BSA/AML compliance framework. Regular reviews help institutions assess whether policies, procedures, and monitoring controls are functioning as intended and keeping paced with current guidance and emerging risks.

Our BSA Audit engagements include targeted testing designed to evaluate:

• Compliance with current FinCEN and regulatory expectations

• Transaction monitoring systems and controls

• Customer Identification Program (CIP) procedures

• Customer Due Diligence (CDD) processes

• Suspicious Activity Report (SAR) procedures and documentation

• Emerging financial crime risks and related controls

  
  

When Was Your Last BSA Audit?

An independent BSA Audit can help identify control gaps, strengthen compliance efforts, and provide management and the board with greater confidence in the effectiveness of the institution’s BSA/AML program.

If we do not currently perform your BSA Audit, we would welcome the opportunity to discuss your institution's needs and how our team can help support your compliance efforts.

Contact us to learn more about our BSA Audit services.