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The independent test is so important because the examiners use it to verify the sufficiency of an institution’s AML program.

The requirements for the independent test are detailed in the FFIEC Examination procedures.  Most importantly, the procedures identify that the test must be conducted by a person or persons not involved with an institution’s BSA/AML compliance staff and report directly to the board or a board committee.

How we can help
We have developed a BSA/AML Independent Test Methodology that fully meets the rigors of the FFIEC Examination Manual.  We closely follow the steps included in the manual and have expanded on them in areas where risk is significant or where we can gain efficiencies in the review.

Staffing.  Most critical is the staff we assign to the projects.  Our BSA/AML team focuses on financial service compliance engagements.  Most team members carry certifications recognized by AML and compliance professionals in the industry.  They are former regulators and bankers who provide clients with timely and relevant reports.

Workpaper documentation.  This is critical to our success.  We are used to having regulators scrutinize our workpapers and have built firm standards that exceed regulatory expectations.

Knowledge of AML systems and processes.  We demonstrate our knowledge via speaking engagements and articles, and by answering day-to-day questions from our clients.

We also recognize that the independent test is a growing expense for financial institutions.  We are constantly seeking ways to streamline our processes to complete the test in less time, while providing the level of service you expect.

A quality independent test process provides more than just a report that demonstrates your compliance with guidelines.