Designation of Individual(s) to Coordinate and Monitor
Compliance
Riggs also lacked effective monitoring for compliance by the BSA officer. Dayto-day
oversight and monitoring of high-risk transactions, high-risk customers, and highrisk
geographies were minimal. Strategies and alternative measures to ensure ongoing
BSA/AML monitoring for suspicious transactions were not adequately developed and
applied. In addition, the person(s) responsible for BSA compliance at Riggs failed to
adequately monitor, identify, investigate, analyze, and report suspicious activity.