BSA-AML Examiner School Case Study eBook

EXPLANATION

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ITEM

After review of the initial list of higher risk customers provided. *The AML examiner will contact the bank with higher risk accounts to be sampled, to include CIP, CDD, account statements, and the last formal review.

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ENHANCED CDD

a.

Suspicious Activity Reporting

AML 8

EXPLANATION

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*AML Examiner will contact the bank on SARs to be uploaded. Please password protect. Provide analysis/documentation of any activity for which a SAR was considered but not filed, or for which the bank is actively considering filing a SAR since the prior examination . Please password protect. Provide information on whether the bank uses a manual or an automated account monitoring system, or a combination of the two. If an automated system is used, is the system proprietary or vendor supplied? If the system is provided by an outside vendor, provide (i) a list that includes the vendor, (ii) application names, and (iii) installation dates of any automated account monitoring system provided by an outside vendor. Additionally, provide a list of the algorithms or rules used by the systems. Provide a list of reports used for identification of and monitoring for suspicious transactions. These reports include, but are not limited to, suspected kiting reports, currency activity reports, monetary instrument records, and funds transfer reports. These reports can be generated from specialized AML/CFT software, the bank’s general data processing systems, or both. *Upon review of the list provided, examiner will contact the bank for the date ranges for review of the various reports.

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SUSPICIOUS ACTIVITY REPORTS (SARs)

a.

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NON-FILED SARs

b.

SUSPICIOUS ACTIVITY MONITORING SYSTEMS

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c.

SUSPICIOUS ACTIVITY MONITORING REPORTS

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d.

Currency Transaction Reporting

AML 9

EXPLANATION

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Provide copies of CTRs filed in December 2023.

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CTRs FILED

a. b.

Provide currency aggregation reports for the weeks of December 18th, 2023 - January 5th, 2024.

CURRENCY AGGREGATION REPORTS

Currency Transaction Reporting Exemptions

AML 10

EXPLANATION

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Provide a list of new/existing customers exempted from CTR filing and the documentation to support the exemption (e.g., currency transaction history or, as applicable, risk-based analysis) and dates exempted.

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LIST OF EXEMPT CUSTOMERS

a. b.

Provide documentation on required annual reviews of CTR exemptions.

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ANNUAL EXEMPTION REVIEWS

Information Sharing

AML 11

EXPLANATION

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ITEM

POSITIVE 314(a) MATCHES

Provide documentation of any positive match(es) for a section 314(a) request.

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a.

SEARCH REQUESTS

Provide documentation demonstrating that required searches have been performed since the last regulatory examination. If applicable, provide a copy of the bank’s most recent notification form to voluntarily share information with other financial institutions under 31 CFR 1010.540 (Voluntary Information Sharing Among Financial Institutions), or a copy of the most recent correspondence received from FinCEN that acknowledges FinCEN’s receipt of the bank’s notice to voluntarily share information with other financial institutions.

b.

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314(b)

c.

Purchase and Sale of Monetary Instruments

AML 12

EXPLANATION

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SALES MONETARY INSTRUMENTS

Provide records of currency sales of monetary instruments in amounts between $3,000 and $10,000 since the last regulatory examination.

a.

Funds Transfers Recordkeeping

AML 13

EXPLANATION

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ITEM

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FUNDS TRANSFERS/WIRES

Provide an excel document of funds transfers, including incoming, and outgoing (foreign and domestic) transfers of $3,000 or more for the last two months. *November 2023, and December 2023. Please provide in an excel document with all the required 'travel rule' fields.

a.

Office of Foreign Asset Control (OFAC)

AML 14

EXPLANATION

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OFAC

Provide the Name and title of the designated OFAC compliance officer and, if different, the name and title of the person responsible for monitoring OFAC compliance. Provide the last full file scrub report on the full customer database and if exceptions noted, comments or reasoning.

a.

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OFAC FULL CUSTOMER REVIEW

b.

E-banking Services-Automated Clearing House Transactions/Remote Deposit Capture/Online Account Opening

AML 15

EXPLANATION

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