BSA-AML Examiner School Case Study eBook

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BSA/AML Policy and Program

PARTY

ROLES AND RESPONSIBILITIES

BSA/AML Officer; and ● Allowing the BSA/AML Officer, or designee, unrestricted access to any business records, systems, or locations necessary to fulfill the duties described in this Policy/Program. Critical Third Parties, including Fintech Partners, are responsible for: ● Maintaining appropriate BSA/AML/OFAC programs, including policies and procedures; ● Complying with contractual requirements; and ● Allowing the Bank access to monitor data, transactions, and documents as contractually obligated. Legal is responsible for: ● Interpreting BSA/AML/OFAC laws and regulations; and ● Providing legal and strategic advice on BSA/AML/OFAC issues and management of risks to the BSA/AML Officer, the management Risk and Compliance Committee, and Board as needed.

Critical Third Parties

Legal 4

6. THE POLICY The Bank’s BSA/AML/OFAC program will consist of the following core components and controls that are described in more detail in the following subsections:

● Designation of a BSA/AML Officer; ● Internal controls, which include:

○ BSA/AML/OFAC risk assessment; ○ KYC program; ○ OFAC compliance; ○ Transaction monitoring;

○ Suspicious activity detection and reporting; ○ Regulatory reporting and recordkeeping; and

4 The Bank may outsource the Legal function.

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Confidential