BSA-AML Examiner School Case Study eBook

Internal Use Only

BSA/AML Policy and Program

All new or modified products and services require approval by the BSA/AML Officer. The BSA/AML Officer evaluates the potential BSA/AML/OFAC risks of new or changed products and services to ensure that any BSA/AML/OFAC risks are appropriately identified and mitigated. The BSA/AML Officer updates TS&J’s risk assessment when new or modified products and services are introduced that materially alter the Bank’s BSA/AML/OFAC risk profile and ensures any additional controls are in place before the Bank adopts the new/modified product or service. Fintech Partners will also be required to notify TS&J’s BSA/AML Officer and the CCO of any new product or service for their review and approval. For additional information on new product/service review and approval, see the Compliance Management System Policy. 3. ONGOINGMONITORING AND TESTING The BSA/AML Officer, working with the Bank CRO, will put in place a regular ongoing monitoring and testing program to ensure that the Bank and Critical Third Parties, including Fintech Partners, continue to maintain high quality BSA/AML/OFAC programs. This is in addition to the independent testing program described below. At a minimum, this monitoring and testing program will review the Bank’s: ● KYC Program; ● Quality of transaction monitoring; ● SAR filing and decisioning; ● CTR filing; ● PA 314(a) responses; ● PA 314(b) handling procedures; ● OFAC screening; ● Law enforcement requests, including subpoenas for AML Review; and ● Oversight of third parties, including Fintech Partners, that impact the effectiveness of TS&J’s BSA/AML/OFAC Program. The BSA/AML Officer will work to ensure that the approach to testing BSA/AML/OFAC compliance is consistent with the Bank’s overarching compliance testing approach. TS&J will conduct this risk-based testing in addition to the Bank’s independent BSA/AML/OFAC testing (see the Independent Testing section below). In addition to being subject to risk-based monitoring from and testing by TS&J, Fintech Partners will also be required to develop a robust approach to ongoing monitoring and testing subject to the review and approval of the BSA/AML

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