BSA-AML Examiner School Case Study eBook

BSA/AML EXAMINER SCHOOL Customer Identification Program

Another BSA Examiner has helped you with your sample and there are 7 more accounts to review for the completed sample of 16 accounts for CIP. The 7 accounts are from different locations and include the BaaS program. Management has provided an upload of the BaaS customer files on the five accounts that you sampled and two community bank CIP forms. We will review one account (Victoria Zaemato) together as a group. Consider the following questions when reviewing the CIP documents.

1) Did management obtain all the information as required for CIP purposes?

2) Has management appropriately checked customers against the OFAC list prior to opening the account?

3) Based on your review, did you identify any exceptions?

4) Do you think the bank has appropriate CIP program procedures?

5) Keep a list of any questions you have for the BSA Officer.

For Training Purposes Only