BSA-AML Examiner School Case Study eBook

REQUEST LIST

Financial Institution - AML/CFT DOCUMENT REQUEST LIST

The list below includes materials that examiners request to be provided (P) for offsite review. Items with an (*P) indicate the bank may need to provide initial information, then/or the Examiner will contact the bank with additional material/transaction sampling requested.

ITEM # AML 1

AML/CFT Compliance Program

EXPLANATION

P/*P

X

ITEM

Provide name and title of the designated AML/CFT (formerly BSA/AML) compliance officer and, if different, the name and title of the person responsible for monitoring AML/CFT compliance.

NAME & TITLE OF OFFICER

P

a.

Provide copies of resumes and qualifications of person(s) new to the program serving in AML/CFT program oversight capabilities. Provide copies of the policy and procedures relating to all reporting and recordkeeping requirements, including suspicious activity reporting. Please provide the dates the policy/procedures, risk assessment, and SARs were approved by the Board.

P

b.

ALL AML/CFT, CIP, AND OFAC RELATED POLICIES AND PROCEDURES

P

c.

Independent Testing

AML 2

EXPLANATION

P/*P

X

ITEM

*AML Examiner will contact bank if access is needed to the audit workpapers.

INTERNAL & EXTERNAL AUDIT WORK PAPERS

*P

a.

AML Training

AML 3

EXPLANATION

P/*P

X

ITEM

Provide AML/CFT training schedule with dates, attendees, and topics. A list of persons in positions for which the bank typically requires AML/CFT training, and those who do not require training (since the last regulatory examination). Provide training documentation (e.g., materials for external training) since the previous AML/CFT regulatory examination. Provide training documentation (e.g., materials used for internal training) since the previous AML/CFT regulatory examination.

P

AML TRAINING REPORTS

a.

P

TRAINING WORKPAPERS-EXTERNAL

b.

P

TRAINING WORKPAPERS-INTERNAL

c.

Regulation GG - Unlawful Internet Gambling Enforcement Act (UIGEA)

AML 4

EXPLANATION

P/*P

X

ITEM

P P

REGULATION GG POLICY

Provide a copy of the current Reg GG policy.

a. b.

NOTICE

Provide the disclosure process on commercial accounts.

Risk Assessment

AML 5

EXPLANATION

P/*P

X

ITEM

P

AML BOARD AGENDAS

Provide AML documentation given to the Board of Directors since the last examination, if not included in the Board minutes.

a.

Customer Identification Program (CIP) and CDD (Beneficial Ownership)

AML 6

EXPLANATION

P/*P

X

ITEM

Provide a list of accounts without Taxpayer Identification Numbers (TINs) or Employee Identification Numbers (EINs). Provide a sample copy of all account opening forms (e.g., for loans, deposits or other accounts) used to document Customer Identification Information, Beneficial Ownership, and Customer Due Diligence information. Provide tracking reports with written description of the bank’s rationale for exceptions. Provide a list of new accounts (including legal entity accounts) covering all product lines (including accounts opened by third parties) and segregating existing customer accounts from new customers, for prior two months. *After new account documents are posted, the AML Examiner will contact the bank with the selected sample for CIP/CDD, Beneficial Ownership, and OFAC. Provide a copy of the customer notice and a description of the timing and delivery, by product. Provide a list of the financial institutions on which the bank is relying, if the bank is using the “reliance provision.” The list should note if the relied-upon financial institutions are subject to a rule implementing the AML/CFT compliance program requirements of 31 USC 5318(h) and are regulated by a federal functional regulator. Provide copies of contracts with financial institutions and with third parties that perform all or any part of the bank’s CIP.

P

TAX IDENTIFICATION NUMBERS

a.

P

ACCOUNT OPENING FORMS

b.

CIP & BENEFICIAL OWNERSHIP EXCEPTIONS

P

c.

LIST OF NEW ACCOUNTS

P

d. e.

CIP CUSTOMER NOTICE

P P

USE OF RELIANCE PROVISION

f.

Customer Due Diligence (CDD)

AML 7