The primary objective of a Systems Assessment is to assess the Banks current suspicious activity monitoring and reporting system.  This includes validating the integrity and accuracy of management information systems (MIS) used in the BSA/AML compliance program.  In addition, the assessment should include a review of the Banks suspicious activity monitoring systems to ensure that the system is comprehensive, adequate, and has the ability to identify unusual activity. 

A System Assessment should include:

• Analysis of the data integrity and transfer process from the core; 
• Analysis of the system’s methodology for establishing and applying expected activity/ profiles or filtering criteria;
• Analysis of the transaction codes used by the core to include recommendations for changes to current structure;
• Analysis of the filtering criteria to determine if they appear reasonable (including ad-hoc reports and alerts);
• Analysis of the suspicious activity reporting systems to determine if it includes an evaluation of the research and referral of unusual activity. 

A Systems Assessmetn should not be designed as nor is it intended to be a full formal audit of the Bank’s BSA/AML program.  The Bank and its management retain sole responsibility for the Bank’s actual implementation of a BSA/AML System, including any policies, procedures and systems.