Understanding the New DFS Part 504 Regulations and the Associated AML Program Testing Challenges

Chris Recor, CAMS-Audit

This paper assesses each of the requirements under Section 302 of the Sarbanes-Oxley Act including examples of program risks, mitigating controls and testing measures that may be used to audit compliance with the Rule. Testing is the cornerstone of auditing the effectiveness of controls of the BSA/AML program. Controls are the system of internal controls (including policies, procedures, and systems) used to mitigate BSA/AML risks. To ensure that the BSA/AML controls are effective the following types of tests should be performed.

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