Assessing Compliance with BSA Regulatory Requirements


Objective: Assess the bank’s compliance with the BSA regulatory requirements for the reporting of foreign 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. Additionally, determine 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. Review the bank’s policies, procedures, and processes for filing annual FBARs to determine whether they meet the BSA regulatory requirements for FBAR reporting.
  3. Determine whether the bank’s internal controls are designed to assure ongoing compliance with FBAR filing requirements and are commensurate with the bank’s risk profile.
  4. Select a sample of accounts subject to FBAR filing requirements to determine whether:
    • FBARs are filed in accordance with FinCEN form instructions.
    • FBARs filed contain accurate and complete information.
    • Any discrepancies exist between the bank’s records of FBARs and the FBARs reflected in the BSA reporting database.
    • The bank has taken corrective action where errors are identified.
    • The bank retains copies (electronic format or paper copies) of FBARs for five years from the date of the report.
  5. On the basis of examination and testing procedures completed, form a conclusion about the adequacy of policies, procedures, and processes the bank has developed to meet BSA regulatory requirements associated with FBARs.


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