Who is responsible for the corrective action following an independent audit of the BSA/AML program?

The institution's management is responsible for taking corrective action following an independent audit of the BSA/AML program. This responsibility arises from the fact that management is charged with overseeing the institution's compliance with regulations and ensuring that effective policies and procedures are in place. After an audit is conducted, management must evaluate the findings, address any deficiencies noted, and implement changes to enhance the institution's compliance efforts.

Management plays a crucial role in cultivating a culture of compliance within the organization and ensuring that the institution meets its regulatory obligations. They must also communicate with the board of directors regarding the audit findings and the actions taken to rectify any issues. This accountability is fundamental for fostering trust with regulators and maintaining the integrity of the financial institution's operations.

Other stakeholders, such as auditors or regulatory authorities, do have roles in the auditing and oversight processes, but they do not have direct responsibility for implementing corrective actions within the institution. The auditors assess and report, while regulatory authorities provide supervision and guidelines, but it ultimately falls to management to translate those insights into tangible improvements in compliance practices.