BANK SECRECY ACT/ANTI-MONEY LAUNDERING
Core Examination Procedures – Scoping and Planning
Identify the bank’s BSA/AML risks and develop the examination scope and plan. This
examination process includes determining examination staffing needs, including
chnical expertise, and selecting examination procedures to be completed.
To accomplish the goals of the BSA/AML examination, the examiner must determine the
BSA/AML risk profile of the bank, as a part of the scoping and planning process.
Whenever possible, the scoping and planning process should be completed before
entering the bank. The scoping and planning process generally begins with an analysis of
off-site monitoring information, prior examination reports and workpapers, request letter
items completed by bank management, the bank’s BSA/AML risk assessment, BSA-
porting databases, and independent reviews or audits.
At a minimum, examiners should perform the procedures included in the following
sections of this manual to ensure that the bank has an adequate BSA/AML compliance
rogram commensurate with its risk profile:
• Scoping and Planning (refer to pages 170 to 173).
• BSA/AML Compliance Program (refer to pages 174 to 178).
Developing Conclusions and Finalizing the Examination (refer to pages 210 to 213).
The core section also includes an overview and procedures for examining a bank’s
policies, procedures, and processes for ensuring compliance with OFAC sanctions. The
examiner should review the bank’s OFAC risk assessment and audit to determine the
extent to which a review of the bank’s OFAC program should be conducted during the
xamination. Refer to “Office of Foreign Assets Control” procedures pages 207 to 209.
To facilitate the examiner’s understanding of the bank’s risk profile and to adequately
establish the scope of the BSA/AML examination, the examiner should complete the
1. Review prior examination or inspection reports, rel