Assessing Compliance with BSA Regulatory Requirements


Foreign Bank and Financial Accounts Reporting

Objective. Assess the bank’s compliance with statutory and regulatory requirements for the reporting of foreign bank and financial accounts.

1. Determine whether the bank has a financial interest in, or signature or other authority over, bank, securities, or other financial accounts in a foreign country, as well as whether the bank is required to file a Report of Foreign Bank and Financial Accounts (FBAR) for customer accounts, including trust accounts, in which the bank has a financial interest or over which it has signature or other authority.

2. If applicable, review the bank’s policies, procedures, and processes for filing annual reports.

Transaction Testing

3. On the basis of a risk assessment, prior examination reports, and a review of the bank’s audit findings, select a sample of accounts to determine whether the bank has appropriately completed, submitted, and retained copies of the FBAR forms.

4. On the basis of examination procedures completed, including transaction testing, form a conclusion about the ability of policies, procedures, and processes to meet regulatory requirements associated with FBARs.


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