BSA/AML Lookbacks

Cendrowski Corporate Advisors frequently works with banks and credit unions to help them assess and implement procedures related to their Bank Secrecy Act (“BSA”) Compliance Programs. Our team members have handled cases involving money laundering at a local and national level and monitored fraud activity for large banks and credit unions. In many situations, we have assisted the bank while they were under FDIC scrutiny.

Our dedicated and experienced team will review, assess and develop the bank’s written program for monitoring and reporting suspicious activity to comply with all applicable requirements of the FDIC’s Rules. We also provide training for the bank board of directors, management, staff, and BSA Staff regarding their responsibilities for identifying and reporting suspicious activity, including filing Suspicious Activity Reports (SAR).

As an independent and qualified third party:

• We perform lookback reviews by reviewing deposit accounts and transaction activity to ensure that all suspicious activity involving any accounts of, or transactions through, the bank were properly identified and reported in accordance with all applicable BSA reporting requirements.
• Advise on BSA Risk Assessment procedures which include all risk areas, including any new products, services, targeted customers, entities, and/or geographic locations.
• Assist banks with the development and implementation of a written Customer Due Diligence (CDD) Program. The program requires a risk focused assessment of the customer base to determine the appropriate level of ongoing monitoring required to ensure that the bank can reasonably detect suspicious activity.
• We conduct enhanced customer due diligence (ECDD) where we perform extensive background and relationship investigations, including in-person interviews, if needed, to document the underlying business arrangements of the customer.