Which of the following is NOT a pillar of the BSA program?

Which of the following is NOT a pillar of the BSA program?

• A. Internal Controls
• B. Independent Testing
• C. BSA Compliance Officer
• D. Business Continuity Planning

Answer: (D)

The BSA program is built around four main pillars that keep the AML framework strong: internal controls, independent testing, a designated BSA compliance officer, and ongoing training for staff. Internal controls establish the procedures and controls to monitor, detect, and report suspicious activity; independent testing provides objective review to ensure the program is functioning as intended; the BSA compliance officer oversees and coordinates the program, ensuring accountability and clear governance; ongoing training keeps employees aware of AML risks and how to recognize red flags.

Business Continuity Planning, while important for keeping operations running during disruptions, does not form one of these core pillars of the BSA program. It’s about resilience and continuity of business activities, not specifically about implementing or maintaining AML controls.