The Case for Independent Audits for Your AML Program

By Lowers & Associates,


One of the most important ways to ensure that your anti-money laundering program is in compliance with Bank Secrecy Act / Anti-Money Laundering (BSA/AML) requirements is to submit it to independent testing or auditing. Regular internal audits are always recommended, but an external auditor has the distance and perspective needed to give you added confidence in your program.

The independent audit should focus on how your organization’s policies, procedures, and processes are organized to support AML compliance. Given the complexity and importance of the issue, it will be critical to hire a consultant who is an expert in the BSA policy intent and the regulatory apparatus that goes with it. Best practice is to conduct the external audit every 12 to 18 months, though banking and credit institutions may have more frequent assessments. … Continue reading

The Important Role of Internal Controls for AML Compliance

By Lowers & Associates,

Internal Control Compliance

It is well understood that money launderers use deceit or theft to capture the processes of financial entities for illicit purposes. As a result, your AML compliance program must implement internal control designs that increase the chances of preventing or detecting such activities.

Financial managers and auditors are familiar with the concept and implementation of internal controls. The difference is that controls as part of an AML compliance program will be focused on mitigating risks discovered in a money laundering risk assessment. Further, internal controls as part of an AML program must be designed to generate the mandated reports and other surveillance, reporting, and records retention required by the Banking Secrecy Act, FinCEN and the Office of Foreign Assets Control, among others. … Continue reading

5 Key Components of a BSA/AML Compliance Program

By Lowers & Associates,


You are most likely familiar with the Financial Crimes Enforcement Network (FinCEN) which is a bureau of the Treasury Department. FinCEN’s mission is “to safeguard the financial system from illicit use and combat money laundering and promote national security” through the use of financial services information.

Bank Secrecy Act (BSA) Anti Money Laundering (AML) regulations previously applied to banks and credit unions, but over the past three decades the law has been expanded to cover a very wide array of financial institutions, maybe even yours. Today, FinCEN maintains webpages for money services businesses (MSB), depository institutions, the insurance industry, securities and futures, casinos, and more. … Continue reading