Oversight of the BSA/AML function is a critical component to ensuring a compliant BSA program.  In accordance with guidance and regulatory expectations, the BSA program should be a written program approved by the Board of Directors.  The expectation is annual approval. Previously, FinCEN’s Chapter X – 1020.210 referred to the four main pillars required for an effective BSA/AML program.  However, with the addition of the beneficial owner requirements, effective May 2018, a fifth category was added to the BSA requirements for on-going customer due diligence. 

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