Frameworks / FFIEC_BSA
FFIEC BSA/AML Examination Manual
FFIEC · US · effective 2021-06-21 · FFIEC_BSA
Independent testing pillar. Requires the tester not be involved in other BSA functions at that institution.
6 controls, mapped to the evidence that satisfies each
Every control links to the dimension whose evidence would satisfy it. That mapping is the working link between an obligation written in law or a standard and a document somebody has to produce. Each row has its own address: link to a single control.
| Control | Title | Requirement | Satisfied by |
|---|---|---|---|
| 31 CFR 1020.210(a)(2)(iv) | BSA training | Appropriate personnel receive training on the BSA/AML obligations relevant to their roles. | D1 |
| IND-TEST | Independent testing | Testing performed by parties not involved in other BSA functions at the institution. | D2 |
| 31 CFR 1010.230 | Beneficial ownership identification | Beneficial owners of legal entity customers are identified and verified at account opening, under both the ownership and control prongs. | D5 |
| 31 CFR 1020.210(a)(2)(v) | Risk-based customer due diligence | Risk-based procedures identify and verify customers, understand the nature and purpose of customer relationships, and conduct ongoing monitoring to support suspicious activity reporting. | D5 |
| 31 CFR 1020.210(a)(2)(i) | Internal controls | A system of internal controls assures ongoing compliance with the Bank Secrecy Act and its implementing regulations. | D6 |
| 31 CFR 1020.210(a)(2)(iii) | Designated BSA compliance officer | An individual is designated as responsible for coordinating and monitoring day-to-day BSA compliance. | D6 |
What this mapping is, and what it is not
It is a reading of a published instrument, with each control cited to its source, mapped to the kind of evidence that would satisfy it. It is not legal advice, not a certification, and not a statement that any organisation complies with anything. Where an instrument is not yet in force, this page says so rather than selling urgency.
Talk to the person who built this
If you assess clients against this instrument, the mapping is the part you can check line by line. There is no sales team: this is founder-led, so it reaches the founder directly. Tenant access is $500 a month, and free early access to the method, the corpus and the router is on offer first if that is useful. If it is not a fit, saying so costs you one reply.