Bank Secrecy Act Examinations

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Bank Secrecy Act Examinations
Sandra Stolt IRS SB/SE BSA Policy Manager July
2007
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SB/SE Compliance BSA Structure

• 385 BSA examiners devote 100 of exam time to BSA
  cases
• Hiring 50 more BSA examiners in FY 2008

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Selection Process

• Methods to select BSA cases for examination
  changing
• Using more top-down approaches such as
• Examine MSB principals
• Examine principal agents

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Selection Process

• Testing a selection process that uses
  statistically valid risk factors
• Working with FinCEN and States to efficiently use
  exchanged MSB information

5
Examination Approach

• Risk analysis in a particular institution
• Risk of money laundering
• Risk of non-compliance
• Developing an MSB Examiners Guide with FinCEN,
  CSBS, and MTRA

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BSA Examinations
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Contact
Sandra Stolt email Sandra.L.Stolt_at_irs.gov Telep
hone 202-615-4033