Answer:
Since 1987, the four pillars of your bank’s formal BSA/AML compliance program have been its:
• internal controls,
• independent testing,
• training, and
• individual responsible for compliance.
A recent amendment to the BSA regulation adds a fifth pillar, “due diligence,” effective in May of 2018. Incorporating it into your compliance efforts will require board action to amend your BSA/AML compliance policy.
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Learn more about Ken Golliher's webinar Annual BSA/AML Roundup
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