BSA-AML Examiner School Case Study eBook

BSA/AML EXAMINER SCHOOL Wire Transfers

You selected a small sample of wires (as there were no concerns on the independent test or last exam on wires for the travel rule regulations). In your sample size, you included two community bank wires and three wires from the new BaaS program incoming wires. Review the wires to ensure all required information is gathered, and wire parties are checked against OFAC as required. (FYI -The wire log incoming/outgoing is also reviewed for suspicious activity, especially foreign wires). Side note: You requested a log of wire on the FinTech side. However, BSA Officer Rose just handed you the three wires to review.

1) Did management obtain all the information required for funds transfer recordkeeping?

2) Did management check all parties in the wire for OFAC purposes?

3) Consider whether the bank has appropriate funds transfer procedures?

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

For Training Purposes Only