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Where to Reference "Internal Control Issue"

Answered by: 
Ken Golliher

Question: 
Currently I am acting as BSA/OFAC Officer, Branch Manager and Loan Officer. Our state/federal regulator just examined our BSA Program and has made mention that she feels like this is an internal control issue. They are recommending that if I need to wear more than one hat it needs to be a different job duty other than branch manager and loan officer. Is this stated anywhere that I can reference the internal control issue for my board of directors? I have reviewed the FFIEC manual and it does not address this direct question.
Answer: 

Your examiner has offered you a personal opinion.

In circumstances like these: feign fascination, pull up your copy of the BSA-AML Examination Manual, and say: "I always learn so much when you guys are here! Where does it say that in the manual?" It doesn't.

Community banks only have so many people to go around. Any BSA officer who is not able to devote "full time" to that position will have other responsibilities. There is no "acceptable" list of other responsibilities you might have, nor is there any "unacceptable" list (outside of the fact that you may not be involved in the independent examination of BSA compliance).

First published on BankersOnline.com 12/10/12

First published on 12/10/2012

Filed under: 
Compliance
Filed under compliance as: 
FFIEC
IT

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