BSA-AML Examiner School Case Study eBook

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Does the bank retain copies of SARs and supporting documentation for five years from the date of filing the SAR?

Yes

Moderate Satisfactory

Assign Inherent Risk → Assign Controls Rating → Assign Residual Risk → Assign Overall Trend →

3 2 2

Limited

Summary of Risk Ratings:

Stable

The Bank's CCO has assumed responsibility for reviewing and submitting SARs and reporting to the Board and the MRCC.

CURRENCY TRANSACTION REPORTING (CTRs)

Yes/No or N/A

Comments and description of mitigating controls

Does the bank maintain internal controls, policies, and procedures for reporting of currency transactions that are designed to assure ongoing compliance with CTR requirements and are commensurate with the bank’s size, complexity and organizational structure? Does the bank electronically file a Currency Transaction Report (CTR) for each transaction in currency (deposit, withdrawal, exchange of currency, or other payment or transfer) of more than $10,000 by, through, or to the bank (and maintain a list of "exempt persons")? Does the bank verify and record the name and address of the individual presenting a transaction, as well as record the identity, account number, and Social Security or taxpayer identification number, if any, of any person or entity on whose behalf such a transaction is conducted? Does the bank have procedures in place to record the specific identifying information (e.g., the driver’s license number) used in verifying the identity of the customer must be recorded on the CTR report? Does management ensure that systems or practices appropriately aggregate currency transactions throughout the bank and report currency transactions subject to the BSA requirement to file CTRs? Does management require the filing of a SAR if it suspects that a person is structuring transactions to evade a CTR?

Yes

Yes

Yes

Yes

Yes

Yes Yes

Does the bank retain copies of CTRs for five years from the date of the report (electronic format or paper copies)?

Moderate Satisfactory

Assign Inherent Risk → Assign Controls Rating → Assign Residual Risk → Assign Overall Trend →

3 2 2

Limited

Summary of Risk Ratings: Stable Retail Leadership reviews CTRs regularly, and the Bank's Operations Team conducts a daily review of transactions that would require a CTR to ensure these are completed timely. CCO maintains oversight of CTRs per the new 2024 Compliance Testing Plan.