State trust companies are subject to the laws of the state in which they are licensed and are overseen by their state regulator. These trust companies are also subject to the Bank Secrecy Act (BSA) (including amending legislation) and federal regulations and overseen by the U.S. Financial Crimes Enforcement Network (FinCEN). FinCEN requires trust companies to establish a compliance program which includes a customer identification program (CIP), due diligence and monitoring program, ​suspicious activity reporting (SAR), currency transaction reporting (CTR), recordkeeping, employee training, and a periodic review of its BSA policies and procedures to ensure that they are adequately designed and effectively implemented.

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I work in tandem with BSA Officers, Compliance Directors, CEOs, and boards to develop, customize, implement, and evaluate internal compliance programs and procedures to ensure compliance with the BSA. My representation includes the following:

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• Advise trusts companies regarding BSA/AML/KYC

• Counsel and prepare clients for regulator examinations

• Conduct independent examinations including fiduciary examinations, complete BSA examinations, SAR look backs

• Act as an ongoing external resource to BSA Officer

• Develop, implement and review corporate policies and procedures, compliance programs and compliance training

 

For more information, you may contact me via my site contact page or directly via e-mail: elizabeth@elizabethmcmorrowlaw.com.

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