Bank Secrecy Act |
Developing Conclusions and Finalizing the Examination-Overview
Objective. Formulate conclusions, communicate findings to management, prepare report comments, develop an appropriate supervisory response, and close the examination.
In the final phase of the BSA/AML examination, the examiner should assemble all findings from the examination procedures completed. From those findings, the examiner should develop and document conclusions about the BSA/AML compliance program’s adequacy, discuss preliminary conclusions with bank management, present these conclusions in a written format for inclusion in the report of examination, and determine and document what regulatory response, if any, is appropriate.
In formulating a written conclusion, the examiner does not need to discuss every procedure performed during the examination. During discussions with management about examination conclusions, examiners should include discussions of both strengths and weaknesses of the bank’s BSA/AML compliance. Examiners should document all relevant determinations and conclusions.
