BSA-AML Examiner School Case Study eBook

BSA/AML EXAMINER SCHOOL TS&J Bank Case Study Introduction

Over the remainder of the week, you will be completing a case study of TS&J Bank. For most areas, we will discuss exam concepts and you will apply the concepts by reviewing materials related to the case study. The case study is based on an actual examination of an institution. However, the personal identifying information of the customers and the institution were changed. Later in the week, the outcomes from the examination will be shared with you. The case study is intended to simulate a BSA examination. As such, you will have the opportunity to ask the BSA Officer [ your instructors ] questions on two occasions. You should write down any questions that you have during the exam planning exercise because the initial BSA Officer interview will occur tomorrow. Later in the week, you will develop your conclusions and conduct a simulated BSA Officer exit meeting (with a group of examiners lasting 30 minutes). To ensure you have a successful experience, you will want to document any potential exceptions, findings, or violations you identify during the transaction testing exercises. These will help you develop your findings and conclusions related to the BSA program at TS&J Bank to discuss with the BSA Officer during the meeting. TS&J Bank is a community bank located in a rural area with total assets of $189 million. The bank is locally owned with four locations (Eagle, Lincoln, Omaha, and Fremont) in Nebraska. In 2022, the bank decided to venture into Banking as a Service (BaaS). In November of 2023 the bank onboarded it first FinTech Client Azul. The bank then onboarded a second client Lemon in December 2023. The ratings from the Fed examination in 9/2022 were 2-2-2-2-3-2/2, with loan problems noted. There was a Matter Requiring Board Attention for Operational Risk Management regarding internal control practices. The prior exam report stated that the BSA program was satisfactory, and the institution satisfactorily complies with OFAC requirements.

For Training Purposes Only