The Audit Impact of the U.S. Department of Justice Prosecution of Bank Secrecy Act Violations

Jason C. Honeycutt, CAMS-Audit

As an institution required to have an “effective AML program,” you must take a two-pronged approach to “effectiveness:” (1) test yourself internally and (2) test yourself by use of an independent auditor. This white paper is designed to assist you to determine what not to do and what to test for based on prior “ineffective” BSA/AML programs, according to public record of civil and criminal cases brought under federal law by the U.S. Department of Justice. This white paper also gives guidance on what the scope of audit of an AML program should include at a minimum, both as a financial institution and as the auditor of a financial institution’s AML program.

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