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Rotter (1990) describes the external locus of control as: 'the degree to which persons expect that the reinforcement or outcome is a function of chance, luck, or fate, is under the control o f powerful others, or is simply unpredictable.'.
The board of directors and management should create a culture of compliance to ensure staff adherence to the bankâs BSA/AML policies, procedures, and processes. Internal controls are the bankâs policies, procedures, and processes designed to limit and control risks and to achieve compliance with the BSA. The level of sophistication of the internal controls should be commensurate with the size, structure, risks, and complexity of the bank.