[mdesso]

Hi there – this Megan Desso the Managing Director for Compliance and Regulatory Services at Shatswell MacLeod and Compliance Anchor. Typically it doesn’t matter what system is used, but any alert must be cleared within 30 days of issue. Most of our client banks are under a $2 billion and working with limited staffing resources relative to BSA, as such many of them don’t have a formal QC process, thus they focus on the actual review and process to properly clear the alert. For our larger institution that do have a QC process they are taking a sample of alerts based on volume and performing a secondary review.

Hope that helps!

[mdesso]

Are you looking for external financial audit firm RFP or outsourced internal audit RFP?

[mdesso]

SMC has not seen any clients making goodwill adjustments if the information is accurate. Goodwill is typically considered in the underwriting process wherein the applicant will write a letter explaining the late payment(s) or other negative information on their credit report.

[mdesso]

Responding to see if we can get the email flow.

[mdesso]

I successfully accessed the MLA website at https://mla.dmdc.osd.mil/ this evening and produced an inquiry with no issue

I have not heard of any other issues.

• This reply was modified 1 year, 1 month ago by mdesso.

[mdesso]

From Melanie Prickett at The First National Bank of Elmer:

The level and type of due diligence should be appropriate for the risks presented by each customer, including charities and other nonprofit organizations. There is no supervisory expectation for banks to have unique, additional due diligence steps for charities or other nonprofit organization customers. There were bulletins/joint releases back in 2020/2021 reminding examiners that the U.S. government does not view the charitable sector as presenting a uniform or unacceptably high risk of being used or exploited for ML/TF or sanctions violations: Joint Fact Sheet on Bank Secrecy Act Due Diligence Requirements for Charities and Non-Profit Organizations

We apply a risk-based approach and evaluate charities according to characteristics using a KYC Form to develop a risk profile, and when deemed higher risk, additional information is gathered using a NPOs & Charities Questionnaire to enhance the risk profile. We established specific guidelines/criteria in determining whether NPOs are high-risk at account opening and ongoing. All accounts [including NPOs] are subject to routine transaction monitoring. Should high-risk factors come up at account opening or from routine monitoring, they would be subject to annual EDD Reviews. This has worked for our Bank’s risk profile; no findings have resulted from our approach.

Hope this helps!

[mdesso]

No it does not but you are not prohibited from issuing a revised LE reflective of the accurate cost, though this does not reset the clock on anything.

[Author]

Posts