BSA-AML Examiner School Case Study eBook

Internal Use Only

For private banking accounts for which a senior foreign political figure is a nominal or beneficial owner, does the bank’s due diligence program include enhanced scrutiny that is reasonably designed to detect and report transactions that may involve the proceeds of foreign corruption?

N/A

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Summary of Risk Ratings:

N/A

SPECIAL MEASURES

Yes/No or N/A

Comments and description of mitigating controls

Does the bank maintain policies, procedures, and processes related to compliance with special measures under section 311 of the USA Patriot Act involving certain foreign jurisdictions, foreign financial institutions, classes of international transactions or types of accounts that are of primary money laundering concern?

Yes

Limited

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2 2 2

Satisfactory

Limited

Summary of Risk Ratings:

Stable

Addressed in the enhanced BSA / AML / OFAC Policy, and annual training.

REPORTS OF FOREIGN FINANCIAL ACCOUNTS

Yes/No or N/A

Comments and description of mitigating controls

Does the bank maintain adequate policies, procedures and processes related to the filing of a Report of Foreign Bank and Financial Accounts (FBAR) that are designed to mitigate and manage money laundering and terrorist financing or other illicit activities? N/A Does the bank file a Report of Foreign Bank and Financial Accounts (FBAR) if that person has a financial interest in, or signature or other authority over, one or more bank, securities, or other financial accounts in a foreign country, and the aggregate maximum value of the accounts exceeds $10,000 at any time during the calendar year (though the BSA E-Filing System)? N/A

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Summary of Risk Ratings:

N/A INTERNATIONAL TRANSPORTATION OF CURRENCY OR MONETARY INSTRUMENTS REPORTING N/A If the bank physically transports, mails, or ships currency or other monetary instruments in an aggregate amount exceeding $10,000 at one time out of or into the United States, does it file a Report of International Transportation of Currency or Monetary Instruments (CMIR) at the time of departure out of or into the U.S.? N/A If the bank receives currency or other monetary instruments in an aggregate amount exceeding $10,000 at one time, which was transported, mailed, or shipped from any place outside the United States, does it file a CMIR within 15 days after receipt (if applicable)? N/A Does the bank maintain adequate policies, procedures and processes related to the filing of a Report of International Transportation of Currency or Monetary Instruments (CIMR)?

Yes/No or N/A

Comments and description of mitigating controls

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Assign Inherent Risk → Assign Controls Rating → Assign Residual Risk →