Pillar 1 – Internal Controls:

The BSA requires banks to have clear rules in place, as it’s about handling money. These rules are called internal controls, meant to ensure that every transaction is properly approved, recorded, and reported. This helps the bank run securely and follow the law.

Banks set up these controls during the start of their BSA program and review them regularly.

Internal controls can also include background checks on employees, reviewing transactions internally, and ways to assess risk. While these might seem like everyday business practices, banks need stronger controls because they face a higher risk of money laundering.

Some common Internal controls include:

• A customer identification program (CIP)
• A transaction monitoring system (TMS)
• An effective compliance culture

Pillar 2 – Designated Compliance Officer:

Every BSA program needs a leader, which is a designated compliance officer. A designated compliance officer’s job is to make sure the bank follows all the BSA rules by:

• Reviewing the bank’s current practices and creating new ones if needed.
• Making sure these new practices fit all the latest BSA regulations.
• Training everyone at the bank on the rules and any changes.
• Talking to regulators and keeping them informed.

The compliance officer is like a BSA expert for the bank. They know the industry well and can answer any questions employees might have.

Pillar 3 – Training and Awareness:

Being in the financial institutions, everyone needs to be provided with proper training and awareness to maintain this pillar of BSA. These training sessions aren’t always the same for everyone. Managers might need more in-depth training than tellers because they handle more sensitive information. But everyone gets trained on the BSA rules and how to spot suspicious activities. Such training is led by BSA experts, like the compliance officer or special companies brought in. Most importantly, these trainings are kept track of. This way, the bank knows who’s been trained on what and when they need a refresher.

Pillar 4 – Independent Reviews:

It’s always better to get assurance from some external professionals. An outside company comes in and makes sure the bank is following all the BSA rules.

Such independent reviews can help find any weak spots in the bank’s system that could lead to problems. These reviewers often work alongside government agencies who also check on banks regularly.

There are two main types of independent reviews:

• On-site Audits: An auditor visits the bank and talks to employees to make sure they’re following the rules.
• External Reviews: A company reviews the bank’s BSA program from the outside.

These reviews help keep the bank’s system strong and make sure it’s following the law.

Pillar 5 – Customer Due Diligence:

The last pillar of the BSA program is all about knowing your customers and their backgrounds. Banks need to understand who their customers are, what kind of business they do, and the potential risks involved in their profile. This helps banks to spot any suspicious activity and avoid risks. This is usually done by:

• Identifying Customers: Banks gather and evaluate information to verify who their customers are by verifying their information using official records and databases such as passports, utility bills, driver’s licenses etc.
• Understanding Business: This includes learning about the customer’s business and where their money comes from. This is done to ensure if the individual is not involved in some illegal business.
• Monitoring Transactions: Here, the banks keep an eye on customer accounts transactions to see if anything unusual happens. Incase of suspicious transactions, check the alerts and file SAR(Suspicious Activity Reports) where necessary.

The Bank Secrecy Act (BSA) might seem like a set of complicated rules, but it’s actually a necessary defense system for our financial well-being. As mentioned above, the BSA program functions with 5 key pillars working together, which are meant to ensure that the banks have a safe financial ecosystem.

Overall, the BSA program safeguards our financial system by preventing financial crimes like money laundering and terrorist financing. By understanding these pillars, we can understand the role they play in keeping our finances safe and ensuring a healthy financial environment for everyone.