Audit Report: Terrorist Financing/Money Laundering. OTS Examinations of Thrifts for Bank Secrecy Act and Patriot Act Compliance Were Often Limited

摘要

The objective of the audit was to determine whether OTS's examination coverage was sufficient to determine thrift compliance with BSA and the Patriot Act. The authors also reviewed how OTS reported the results of its examinations to ensure that thrifts took appropriate corrective actions for noncompliance with BSA. Using OTSs guidance for conducting and reporting BSA examinations, they reviewed the most current examinations conducted by OTSs four regions for a sample of 95 thrifts. Upon selecting current examinations for review that covered the period of calendar years 2004 through 2006, they requested and reviewed the examinations performed just prior to these examinations, usually 12 to 18 months earlier, to compare the scope of both examinations and determine whether problems previously identified in the BSA program had been corrected. The authors also interviewed the examiners for the sampled thrifts to discuss their observations relative to the reviewed examinations. They conducted their fieldwork from January 2006 through July 2007. Appendix 1 contains a more detailed description of audit objectives, scope, and methodology.