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BSA Independent Review Dashboard (Banks)
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The BSA Independent Review - Self Audit Dashboard is an easy to use application that breaks the FFIEC manual down into component questions, thus providing a superior tool to keep you informed as to the standing of your BSA AML program. The program comes with an extensive Help file containing a great deal of guidance on BSA topics, the FFIEC manual, the Regulations, as well as a Getting Started Section to, well, get you started! The contents of the the Help is also completely searchable � thus giving you access to a huge, up to date compilation of BSA guidance from numerous sources (e.g., FFIE, FATF, other FIU�s such as CATF, The UN, and other US government agencies). It affords you all the capabilities to perform a self assessment of your institution�s BSA compliance risks. A smart thing to do ahead of any audit by a regulator! There is also a free two week trial available to CheckForRisk, a search engine tool for BSA purposes that knocks the socks off Google, LexisNexis news, and World-Check. And (as they say on TV), that's not all! There is also a HIFCA/HIDTA search tool included that lets you search by counties and zip codes to determine whether a customer is located in either a HIFCA or HIDTA. So what are you waiting for? Join the ImpactAML community of users and just say no to outrageous BSA compliance costs. Download, use, enjoy -- and stay out of trouble!! (What kind of trouble? See the excerpt from the American Express Bank Assessment of $25 million Civil Monetary Penalty below!) (The checklist was last updated in February 2007) (The photos below are screenshots of the Checklist's compliance Dashboard. They gives you an idea of the depth of the program's coverage. The third and fourth pictures below are a graphical depiction of the status of a user's checklist progression (zero in this case!), and portions of the Help File index. Reports can also be generated from the data.

Your Internal Auditors should definitely download and use this BSA Checklist to avoid the fate of American Express Bank International (see following)...

From the Assessment of Civil Monetary Penalty:

American Express Bank International's independent testing of its Bank Secrecy Act program was ineffective. Internal Audit Staff lacked sufficient training and knowledge to facilitate compliance with the Bank Secrecy Act. Audit scopes were not always tailored or designed to capture and test for compliance with certain requirements of the Bank Secrecy Act. Internal Audit staff also failed to conduct sufficient customer transaction testing to adequately evaluate the overall sufficiency of the anti-money laundering program at the Bank. Furthermore, Internal Audit failed to assist management with tracking and following-up on previously identified regulatory examination deficiencies. In addition, Internal Audit failed to conduct adequate testing of the suspicious activity monitoring system or identify the numerous data integrity concerns associated with this system for an extended period of time. The ineffectiveness of the Internal Audit function at American Express Bank International contributed to the failure to identify significant deficiencies in this system before 2007.