Introductory BSA/AML Examiner School, Providence, RI

under section 312 of the USA PATRIOT Act (31 CFR 1010.610 and 1010.620).

Comment: 8. Describe the board of directors’ and senior management’s commitment to BSA/AML compliance. Consider whether management has the following: • A strong BSA/AML compliance program fully supported by the board of directors. • A requirement that the board of directors and senior management are kept informed of BSA/AML compliance efforts, audit reports, any compliance failures, and the status of corrective actions. Comment: 9. Describe whether the bank’s policies, procedures, and processes for SAR filings meet the regulatory requirements and are effective. Comment: 10. Describe whether the bank’s policies, procedures, and processes for large currency transactions meet the requirements of 31 CFR 1010.311 and 1010.313) and are effective. Comment: 11. If applicable, describe whether the bank’s policies, procedures, and processes for CTR exemptions meet regulatory reporting requirements, appropriately grant exemptions, and use the correct forms. Comment: 13. Describe the bank’s recordkeeping policies, procedures, and processes. Indicate whether they meet the requirements of 31 CFR Chapter X. 12. Describe whether the bank’s funds transfer policies, procedures, and processes meet the requirements of 31 CFR 1020.410(a) and 1010.410(f). Briefly discuss whether the policies, procedures, and processes include effective internal controls (e.g., separation of duties, proper authorization for sending and receiving, and posting to accounts), and provide a means to monitor transfers for CTR reporting purposes. [1] The Federal Reserve, the FDIC, and the OCC each require the U.S. branches, agencies, and representative offices of the foreign banks they supervise operating in the United States to develop written BSA compliance programs that are approved by their respective bank’s board of directors and noted in the minutes, or that are approved by delegates acting under the express authority of their respective bank’s board of directors to approve the BSA compliance programs. “Express authority” means the head office must be aware of its U.S. AML program requirements and there must be some indication of purposeful delegation. For those U.S. branches, agencies, and representative office of foreign banks that were already in compliance with existing obligations under the BSA (and usual and customary business practices), the BSA compliance program requirement should not impose additional burden. Refer to 71 Fed. Reg. 13936 (March 20, 2006). Refer to [2] The Board of Governors of the Federal Reserve System requires Edge and agreement corporations and U.S. branches, agencies, and other offices of foreign banks supervised by the Federal Reserve to establish and maintain procedures reasonably designed to ensure and monitor compliance with the BSA and related regulations (refer to Regulation K, 12 CFR 211.5(m)(1) and 12 CFR 211.24(j)(1)). In addition, because the BSA does not apply extraterritorially, foreign offices of domestic banks are expected to have policies, procedures, and processes in place to protect against risks of money X1A5T Comment: Comment: