Can meeting BSA requirements assist in my SOX effort? 

In my banking career, I very quickly learned to appreciate and agree with the feeling of most bankers that the financial industry is among the most highly regulated in the country. As banking processes have become more sophisticated, and the world has become smaller with a larger appetite for financial abuse, additional and more complex regulations have been introduced. The Bank Secrecy Act ranks high among these recent regulatory requirements.

Taking the position that mandated compliance with The Bank Secrecy Act will in some ways make Sarbanes-Oxley compliance smoother, the similarity in the definition of each is noted. For example:

Bank Secrecy Act: “Examination procedures are designed to determine if the bank’s policies, procedures and internal controls are adequate. This includes bank compliance audit reports.”

Sarbanes-Oxley Act: The primary goals of Sarbanes-Oxley include the “responsibility of management for establishing and maintaining an adequate internal control structure.”

The strict regulatory environment in which banks and bankers operate may actually enhance their transition to mandatory compliance with Sarbanes-Oxley. The apparatus already exists in financial institutions to establish procedures, monitor compliance, remediate exceptions, and report results, indicating that the nucleus for compliance with Sarbanes-Oxley is already in place. With these existing assets in place, the missing ingredient is an independent assessment of existing processes resulting in a thorough and concise roadmap for compliance. Bankers must be aware, that the manner in which internal control information is relayed to the external auditors is extremely important. External auditors and regulatory authorities are likely to have differing expectations relative to presentation. Therefore, a well planned and organized documentation plan will help bridge any gaps between compliance groups.

The independent assessment phase of Sarbanes-Oxley compliance and the development and monitoring of the roadmap for success is a major strength of Visage Solutions, LLC. Visage has been involved in helping organizations navigate compliance with SOX since the inception of the act in 2002. In addition, Visage brings additional strengths to its banking initiatives, with seasoned senior banking experience on staff, and the ability to utilize Information Technology expertise to integrate all of the banking compliance initiatives into a seamless whole. Simplistically, it is analogous to the old money bags that we all fondly remember: regulatory compliance including BSA and Sarbanes are placed into the money bag, and IT provides the “string” to close the bag and tie up the loose ends creating success. The relationship between Information Technology and Sarbanes Oxley was discussed in detail in the Visage Solutions communication in early September. As an enhancement to that white paper and a quick opportunity for your assessment of the Information Security aspects of your Information Technology Systems, Visage has provided a link to a security questionnaire for your use. 

Our Team
Our team is comprised of experienced executives, managers and consultants who will assist your banking organization in the development, implementation and execution of comprehensive risk management and compliance strategies.  From the initial passage of  Sarbanes-Oxley in 2002, Visage has provided solutions to a client base ranging from private, entrepreneurial companies to large multinationals. 

Our Value 

    • Utilizing our proprietary SingleVue™ compliance methodology, we tailor comprehensive, cost-effective and flexible solutions to our clients.
    • Our solutions enhance your current business processes, rather than adding unnecessary overhead, thus creating measurable long-term value.
  • We involve your executive team, including your internal and external advisors, to guarantee solutions are absolutely consistent with your requirements.
  • We allow you to concentrate on managing your business.

 

 


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