Key Elements of a Bank Secrecy Act Compliance Program

C

The Bank Secrecy Act (BSA) requires financial institutions, including banks, to establish and implement a comprehensive compliance program to prevent and detect money laundering, terrorist financing, and other financial crimes. The Compliance Risk Management (CRCM) certification from the American Bankers Association (ABA) focuses on the development and implementation of effective compliance programs.

To answer the question, the correct answer is option C: Designation of individuals responsible for day-to-day compliance. This is because a bank's BSA compliance program should include the designation of individuals or teams responsible for day-to-day compliance with the BSA and related regulations. These individuals or teams should have the necessary authority, independence, resources, and access to information to effectively implement the compliance program.

Option A is incorrect because lobby notice requirements are not specific to BSA compliance. Instead, they are related to consumer protection laws and regulations, such as the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA).

Option B is incorrect because the one-year record retention requirement is only one aspect of the BSA compliance program. The BSA requires financial institutions to maintain records for a specified period, but the compliance program should also include policies and procedures for customer due diligence, suspicious activity monitoring and reporting, currency transaction reporting, and other key areas.

Option D is incorrect because the BSA does not specifically cover types of loans. Instead, it applies to all financial transactions, including deposits, withdrawals, transfers, and loans, that involve currency, checks, or other monetary instruments.

In summary, a bank's BSA compliance program should include the designation of individuals or teams responsible for day-to-day compliance, as well as policies and procedures for customer due diligence, suspicious activity monitoring and reporting, currency transaction reporting, record retention, and other key areas.