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Regulatory examinations can be stressful, but thorough preparation significantly improves outcomes. Whether you’re expecting OCC, Federal Reserve, FinCEN, or state examiners, this guide will help you prepare.
📅 Pre-Examination Preparation (3-6 Months Out)
Self-Assessment
- Conduct a mock examination using the FFIEC BSA/AML Examination Manual
- Review and close any outstanding audit findings or MRAs
- Ensure all policies and procedures are current and approved
- Validate that training records are complete and accessible
Documentation Organization
- Create an examination preparation binder with key documents
- Compile risk assessment documentation with supporting analysis
- Organize board and committee meeting minutes showing BSA oversight
- Prepare transaction monitoring system documentation and validation results
Personnel Preparation
- Brief key staff on examination expectations and communication protocols
- Designate examination liaisons for each functional area
- Refresh staff on their specific roles and responsibilities
📋 Key Documents Examiners Will Request
| Category | Documents |
|---|---|
| Governance | BSA/AML policy, board approvals, committee minutes, org chart |
| Risk Assessment | Enterprise-wide risk assessment, customer risk rating methodology |
| CDD/EDD | CIP procedures, EDD documentation samples, beneficial ownership files |
| Transaction Monitoring | System documentation, rules/scenarios, validation results, tuning history |
| SAR Filing | SAR filing statistics, sample SAR narratives, decision documentation |
| Training | Training curriculum, completion records, specialized training documentation |
| Independent Testing | Internal audit reports, external audit reports, remediation status |
🗣️ Examination Interview Tips
For BSA Officers
- Be prepared to discuss your program’s strengths and areas for improvement
- Demonstrate knowledge of your institution’s specific risk profile
- Explain your resource allocation and how it aligns with risk
- Show evidence of BSA ownership at the board level
For All Staff
- Answer questions directly and honestly
- If you don’t know the answer, say so and offer to follow up
- Don’t speculate or provide information outside your area of expertise
- Maintain professional composure throughout
🚨 Common Examination Findings to Avoid
- Incomplete risk assessments – Missing products, services, or customer types
- Outdated policies – Not reflecting current regulatory requirements
- Insufficient training documentation – Gaps in completion records
- Inadequate transaction monitoring coverage – Gaps in scenarios or products monitored
- Weak SAR narratives – Insufficient detail or missing key elements
- Unresolved prior findings – MRAs or audit issues still outstanding
Preparing for an examination? Our team provides comprehensive exam readiness assessments.