BSA-AML Examiner School Case Study eBook

Internal Use Only

No change in risk from previous years.

FUNDS TRANSFERS RECORDKEEPING

Yes/No or N/A

Comments and description of mitigating controls

Does the bank obtain all applicable records for each payment order in the amount of $3,000 or more that it accepts as an originator's bank (such as name and address of the originator, amount of payment order, date of payment, identity of beneficiary's institution, etc.)? If a payment order is made in person, does the bank verify the identity of the person placing the payment order before it accepts the order (and retain those records)? If a payment order is NOT made in person, does the bank obtain and retain the following records (name and address of person placing payment order, TIN, SSN, EIN or alien ID) before it accepts the order?

Yes

Yes

Yes Yes

Does the bank retain all funds transfer records for five years?

Limited

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

2 2 2

Satisfactory

Limited

Summary of Risk Ratings:

Stable

No change in risk from previous years. FOREIGN CORRESPONDENT ACCOUNT RECORDKEEPING, REPORTING AND DUE DILIGENCE Does the bank take reasonable steps to ensure that any correspondent account established, maintained, administered, or managed in the United States for a foreign bank is not being used by that foreign bank to provide banking services indirectly to foreign shell banks? If the bank maintains a correspondent account for a foreign bank, does it retain records identifying the owners of each foreign bank and record the name and street address of a person who resides in the U.S. and is authorized to be an agent and accept service of legal process? Does the bank have an established due diligence program that includes appropriate, specific, risk-based, and, where necessary, enhanced policies, procedures, and controls that are reasonably designed to enable the bank to detect and report, on an ongoing basis, any known or suspected money laundering activity conducted through or involving any correspondent account established, maintained, administered, or managed in the United States for a foreign financial institution?

Yes/No or N/A

Comments and description of mitigating controls

N/A

N/A

N/A

Summary of Risk Ratings:

- - -

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

N/A

PRIVATE BANKING DUE DILIGENCE PROGRAMS (NON-U.S. PERSONS)

Yes/No or N/A

Comments and description of mitigating controls

Does the bank have policies, procedures, and controls to detect and report money laundering and suspicious activity through private banking accounts established, administered, or maintained for non-U.S. persons? Has the bank established appropriate, specific, and, where necessary, EDD policies, procedures, and controls that are reasonably designed to enable it to detect and report instances of money laundering through such accounts? Does the bank monitor deposits and transactions as necessary to ensure that activity is consistent with information that it has received about the client’s source of funds and with the stated purpose and expected use of the account?

N/A

N/A

N/A