Internal Audit

Compliance Audits

A compliance audit is a comprehensive review of an organization’s adherence to regulatory guidelines.

We provide the following Compliance Audit:

  • Credit decisioning & Governance
  • Commercial Lending
  • Consumer Lending
  • Financial Services Regulatory Compliance.

BSA/AML Compliance

The Currency and Foreign Transactions Reporting Act of 1970—which legislative framework is commonly referred to as the “Bank Secrecy Act” (BSA)—requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering.

Under the Bank Secrecy Act (BSA) and related anti-money laundering laws, banks must:

  • Establish effective BSA compliance programs
  • Establish effective customer due diligence systems and monitoring programs
  • Screen against Office of Foreign Assets Control (OFAC) and other government lists
  • Establish an effective suspicious activity monitoring and reporting process
  • Develop risk-based anti-money laundering program
  • financial institutions are also required to assist U.S. government agencies in detecting and preventing money laundering, such as:
  • Keep records of cash purchases of negotiable instruments,
  • File reports of cash transactions exceeding $10,000 (daily aggregate amount), and
  • Report suspicious activity that might signal criminal activity (e.g., money laundering, tax evasion).
  • Perform Independent testing of the BSA Program.

The purpose of independent testing (audit) is to assess the bank’s compliance with BSA regulatory requirements, relative to its risk profile, and assess the overall adequacy of the BSA/AML compliance program. Independent testing should be conducted by the internal audit department, outside auditors, consultants, or other qualified independent parties.1 Banks that do not employ outside auditors or consultants or do not have internal audit departments may comply with this requirement by using qualified bank staff who are not involved in the function being tested. Banks engaging outside auditors or consultants should ensure that the persons conducting the BSA/AML independent testing are not involved in other BSA-related functions at the bank that may present a conflict of interest or lack of independence, such as training or developing policies and procedures

TFG conducts independent audit of national banks, federal savings associations, federal branches, and agencies of foreign banks in the U.S. to assess their program compliance with the BSA. Our approach is to provide a risk base and unbiased appraisal of each of the required elements of the company’s anti-money laundering program, including its Bank Secrecy Act-related policies, procedures, internal controls, recordkeeping and reporting functions, and training.

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