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Independent Testing
Riggs did not implement an adequate system for independent testing of BSA
compliance. The independent testing for compliance with the BSA was neither timely
nor effective for the level of risk within Riggs. The internal audit could not verify that
management’s corrective action for identified deficiencies were effective or timely. In
addition, the scope of the audit failed to include an evaluation of the areas of money
laundering vulnerabilities, BSA compliance, or the suspicious activity reporting process.
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