Compliance Blog

The Office of Thrift Supervision recently hit Washington Mutual Bank (WaMu) with a cease and desist order.  Sure, this is a C&D issued by another regulatory agency.  The Compliance Guy finds these useful however.  BSA is BSA, or so they say.  One can easily take lessons from other agencies.  The C&D does not go into details about what WaMu did wrong.  Rather, it lists numerous items that WaMu must do to come into compliance.  Here are a few:

1. Strengthening internal controls, which includes adequate staffing and training.
2. Enhancing of independent testing.
3. Providing adequate resources and authority for its BSA compliance officer.

You can read the rest for yourself through the link provided above.  Why did I underline item 3?  I think it is often overlooked.  The best policies, procedures and reports are not worth a doodle if a BSA compliance officer does not have the time, training, resources or authority to make things happen. 

Reading enforcement actions is a good way to see compliance from a different angle.  These orders generally provide detailed instructions to financial organizations on how to improve their compliance performance.  That makes them good reads.

Here's a link to NCUA's enforcement actions.
Here's a link to OTS' enforcement actions.
Here's a link to OCC's enforcement actions.
Here's a link to FinCEN's enforcement actions.