Action Plan to Maintain a Robust BSA/AML Compliance Program

It is imperative for banks and other financial institutions to develop and implement an action plan to address the heightened regulatory scrutiny and program risks.

Below is an action plan to guide you.

1. Commit Sufficient Resources to Ensure a Strong Compliance Program

An institution must be able to demonstrate to regulators that it has committed the necessary resources – and is willing and able to invest additional resources, as appropriate – to establish and maintain a robust BSA/AML and OFAC compliance program, including investments in technology, staff, training, and monitoring capabilities.

2. Maintain the Strength of Information Technology and Monitoring Processes

In addition to maintaining updated IT software and programs, management and the board of directors of an institution should ensure adequately trained staffing to monitor and supervise these processes and programs.

3. Risk Management

Banking regulators will examine institutions with a focus on ensuring that senior management and the board have taken the time to identify the particular risks posed by an institution’s business model and have designed a BSA/AML and OFAC compliance program that address such risks.

4. Small Institution Risks

Smaller institutions should identify particular lines of business or geographic regions that pose higher risks, and ensure such risks are specifically reflected and addressed in their BSA/AML and OFAC compliance program, policies and procedures.

A Broadleaf Group Banking Consultant can provide guidance with a no-cost assessment of your compliance program. Call 1-866-837-4103 or fill out the form in the right sidebar to get started.


Click this link to join the Bank Secrecy Act/ Anti-Money Laundering Roundtable Networking Group on LinkedIn. This group serves as an online gathering place for banking professionals to discuss a variety of topics including:

BSA/Officers General Role and Responsibilities
Employee Training
Current Regulatory Challenges
Enhancing the Risk Assessment
Enhancing Risk-Based Approaches to AML

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