BSA-AML Examiner School Case Study eBook

Internal Use Only #

ABA Training Details

Schedule/Due Dates

Notes

Tab #

2024

2023

2022

2020

2021

Course Title

Retired

Course Description

N/A Builds the customer identification and due diligence process for specific types of accounts believed to pose increased risks of money laundering and terrorist financing, and explains how the USA PATRIOT Act affects sharing of certain types of information between financial institutions and law enforcement officials. N/A Provides key information relative to OFAC laws and regulations that are part of bank employees' daily responsibilities. Explains the overall purpose and background of OFAC. Describes the purpose and use of the blocked persons list, as well as the general guidelines for handling matched names and blocked funds.

Course was required 2020-2023 for Retail employees (*Head of Retail exception). Course is required for 2024 for all employees (*CEO/CRO exception). Course was required 2020-2023 for Retail employees (*Head of Retail exception). Course is required for 2024 for all employees (*CEO/CRO exception). Course was required for all employees (*CEO exception) in 2020-2021, but course was retired 1/1/2022. Course was not required, was taken by one employee for extra training Course was not required 2020-2021. Course was required for all employees (*CEO exception) for 2022-2023. Course is required for 2024 for all employees and all new hires. Course was not required 2020-2023, was taken by one employee for extra training. Course is required for 2024 for Retail employees Course was required 2020-2023 for Retail employees (*Head of Retail exception). Course is required for 2024 for All Retail (*part-time teller exception) and Commercial Lending. Course was not required 2020-2023, was taken by one employee for extra training. Course is required for 2024 for Retail and Commercial Lending employees Course was required 2020-2023 for Retail employees (*Head of Retail exception). Course is required for 2024 for All Retail and Operations employees.

BSA/AML: USA Patriot Act

1

Q3 (9/30/2020) Q3 (9/30/2021) Q3 (9/30/2022)

Q3 (9/30/2023) Q3 (9/30/2024)

2

Office of Foreign Assets

Q3 (9/30/2020) Q3 (9/30/2021) Q3 (9/30/2022) Q4 (12/31/2023) Q1 (3/31/2024

3 BSA/AML: Overview 1/1/2022 N/A - Cannot be viewed due to being retired

Q2 (6/30/2020) Q2 (6/30/2021)

No

No

No

BSA/AML: Complying with the BSA

4

1/1/2022 N/A - Cannot be viewed due to being retired

No

No

No

No

No

N/A Understand the basic elements of the Bank Secrecy Act (BSA), originally the Currency and Foreign Transactions Act of 1970 but amended over time, and its associated compliance expectations. This course covers the three stages of money laundering and the requirements for a Bank Secrecy Act compliance program. It also describes the key parts of a BSA/AML policy, explains the importance of identifying customers, monitoring transactions, filing reports and retaining records, and outlines the possible penalties for non-compliance. No N/A Describes the two-step process to obtain types of identifying information from customers, and risk-based procedures to verify information. Explains the procedures to maintain records of the information used to verify identifying information. Explores different ways to disclose the CIP notice at account opening. No N/A Explains the additional CIP steps to take at account opening to identify customers and confirm that their activities and funds are legitimate. Describes the documentation and enhanced due diligence the bank may require for non-U.S. persons, and risks to the bank when offering services to higher risk entities.​ N/A Provides information on FinCEN’s CDD Rule that amends existing BSA regulations, and requirements to identify and verify the identity of beneficial owners of legal entity customers, subject to certain exclusions and exemptions. Describes the pillars of BSA/AML compliance under the CDD Rule and the core elements of customer due diligence. No N/A Explains the need for and parameters of currency transaction report (CTR) filing as well as the key aspects of completing electronically filed CTRs, and CTRs for common carrier deliveries. Provides examples of multiple transactions and explains aggregation at various levels including customer, account, and conductor focused CTRs. N/A Teaches how to explain to customers that the bank is required by law to collect and retain certain records, or make particular reports. Explains how the FinCEN’s educational pamphlet, “Notice to Customers: A CTR Reference Guide” can be used as a resource to help address questions frequently asked by customers. No Explains both phases of the exemption process and the information that is needed and lists the business entities that are not eligible for exemption from CTR reporting. Discusses the reasons for possible decisions to revoke customer exemptions. No N/A Describes the BSA requirements for a bank to file a Suspicious Activity Report and why federal law limits sharing information about a SAR, and the components of a SAR monitoring and reporting system, and how to answer the essential questions that comprise the basis of the SAR narrative. N/A Explains the requirements needed to complete the Currency Transaction Report (CTR) and the Designation of Exempt Person (DOEP). Describes the BSA required Report of International Transportation of Currency or Monetary Instruments Report (CMIR), the Report of Foreign Bank and Financial Accounts (FBAR), the Suspicious Activity Report (SAR), and SAR filing requirements. No No N/A

BSA/AML: Fundamentals

5

Q2 (6/30/2023) Q3 (9/30/2024)

Q2 (6/30/2022)

No

6

Q2 (6/30/2024)

BSA/AML: CIP Basics

No

No

No

BSA/AML: CIP Advanced

7

Q4 (12/31/2022 Q3 (9/30/2021) Q4 (12/31/2022) Q4 (12/31/2023) Q2 (6/30/2024)

BSA/AML: Beneficial Ownership and Customer Due Diligence BSA/AML: Completing the CTR BSA/AML: Communicating with Customers about CTRs BSA/AML: Exempting Customers from CTR Reporting

8

Q2 (6/30/2024)

No

No

No

9

Q3 (9/30/2020) Q3 (9/30/2021) Q3 (9/30/2022)

Q3 (9/30/2023) Q3 (9/30/2024)

10

No

No

Q2 (6/30/2023) Q3 (9/30/2024) Course was not required 2020-2022. Course was required in 2023 again in 2024 for all Retail and Operations employees.

11

Q2 (6/30/2024) Course was not required 2020-2023. Course is required in 2024 for Retail Managers and All Operations employees

No

No

No

Course was not required 2020-2023. Course is required for 2024 for all employees (*CEO/CRO exception) and all new hires. Course was not required 2020-2023. Course is required for 2024 for all Retail and Operations employees and required for all new hires. Compliance employees are required to take all courses assigned out for 2024.

12 BSA/AML: SAR Filing

Q3 (9/30/2024)

No

No

No

13 BSA/AML: Reporting

No

No

No

Q3 (9/30/2024)

For Training Purposes Only