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.