BSA-AML Examiner School Case Study eBook

Internal Use Only

PRODUCTS

Yes/No or N/A

Comments and description of mitigating controls

Does the bank offer higher-risk products such as commercial letters of credit or other trade finance products, foreign correspondent bank accounts, payable-through accounts, nonresident alien accounts, foreign customer accounts or concentration accounts? Does the bank compare all new accounts with the OFAC list prior to being opened or shortly thereafter (i.e. during nightly processing)? - Is the documentation of these checks maintained?

No

Yes

Does the bank have a procedure for screening existing accounts on a regular basis?

Yes

Does the bank have procedures for screening Automated Clearing House (ACH) transactions (both domestic and cross-border)?

Yes

Does the bank offer wire transfers (foreign or domestic)? - Does the bank have procedures for screening these transfers prior to execution?

Yes

Does the bank offer stored-value cards? - If yes, does it have procedures for screening purchasers if the card is considered high risk (such as purchased by non-customer and reloadable via a third-party? Does the bank offer e-banking? - If yes, does it have procedures for transaction monitoring or does it rely on third-party providers?

Yes

Yes

Does the bank offer non-deposit investment products or insurance? Does the bank complete a risk assessment for higher-risk products that it offers?

Yes Yes

Limited

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

2 2 2

Satisfactory

Limited

Summary of Risk Ratings: Stable The new CCO (as of June 2023) implemented additional steps for OFAC processing including clarity on clearing of false positives, as well as training. The Bank rolled out a new program for New Accounts (BPM) which incorporates an automated OFAC screen for new clients. Wires and ACH are generally automated. Additionally, the Bank Compliance team began OFAC testing and oversight in November 2023. SERVICES Yes/No or N/A Comments and description of mitigating controls Does the bank offer higher-risk services such as international funds transfers, cross-border ACH transactions, transactional electronic banking or international private banking? Yes Does the bank have customer's that operate privately owned ATM's? No Does the bank offer cryptocurrency services? No Does the bank utilize third-party payment processors? No Does the bank offer trust and asset management services, domestic private banking, or trade financing activities? No Does the bank complete a risk assessment for higher-risk services that it offers? Yes

Moderate

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

3 2 2

Satisfactory

Limited

Summary of Risk Ratings:

Stable