Which component is NOT part of the five core elements of a BSA program?

The five core components of a Bank Secrecy Act (BSA) program are crucial for ensuring compliance with anti-money laundering and other regulatory requirements. The correct choice, which indicates an element that is NOT part of the core BSA program, is the Financial Performance Review.

The other options—System of Internal Controls, Independent Testing, and BSA Compliance Officer—are essential components. The System of Internal Controls is necessary to prevent and detect financial crimes and ensure that all necessary procedures are followed effectively. Independent Testing acts as a way to assess the adequacy and effectiveness of the BSA program, providing an external review to identify weaknesses or gaps. The role of a BSA Compliance Officer is critical as it designates someone responsible for overseeing and managing the compliance efforts within the organization.

While understanding financial performance is important for a credit union’s overall health, it does not directly correlate with the requirements for a BSA program. The focus of the BSA program is on compliance and risk management related to money laundering and terrorist financing, which the other components address directly.