Bank Secrecy Act Audit (BSA)

Bank Secrecy Act/Anti-Money Laundering Audit (BSA/AML Audit)

The Bank Secrecy Act (BSA), as strengthened by the Patriot Act in 2001, is one of the most comprehensive yet one of the most violated regulations on the books. Its enhanced member identification requirements, due diligence procedures, and information sharing requirements between the credit union and the government create a challenging set of issues. A CastleGarde professional is able to perform and deliver a full BSA audit for your credit union.


The Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Audit is intended to assess the effectiveness of the credit union’s BSA/AML compliance program and the credit union’s compliance with the regulatory requirements pertaining to the Bank Secrecy Act, including a review of the credit union’s risk management practices.


CastleGarde’s BSA/AML Audit is divided into fourteen facets. Each facet includes many audit items that a CastleGarde professional will examine during the course of the audit. The audit is conducted through a combination of questions, staff interviews, direct observation, a sample review, and testing.

The BSA/AML Audit includes a review of the credit union’s risk assessment of its products and services, written BSA/AML compliance program, internal controls, and member identification procedures. CastleGarde reviews the filing, accuracy, meeting of deadlines, and retention by the credit union of the various BSA/AML reports to ensure compliance.


At the conclusion of the audit, CastleGarde conducts an exit interview summarizing the audit and sharing any high-priority findings.

At a later date, CastleGarde issues specific recommendations in a comprehensive written report that outlines what is necessary to eliminate and correct deficiencies in the credit union’s BSA/AML compliance as determined by the audit.