BSA-AML Examiner School Case Study eBook

Internal Use Only No change from previous years. Bank continues to maintain oversight of risk for ACH and wire transfers, and additional services and providers.

CUSTOMERS & ENTITIES

Yes/No or N/A

Comments and description of mitigating controls

Does the bank complete the initial identification of higher-risk customers as part of its CIP and CDD procedures?

Yes

Does the bank have a large number of higher-risk customers? - Has the number of customers grown over the last year?

No

Does the bank have a large number of MSB (Money Service Business) customers? - Has the number of customers grown over the last year? Does the bank identify and monitor large dollar amount or high frequency transaction accounts? Does the bank offer accounts to foreign customers, corporations, or deposit brokers? Does the bank offer accounts to nonresident aliens or politically exposed persons? Does the bank offer accounts to non-bank financial institutions, non-governmental organizations or charities?

No

Yes

No

However, these will be monitored per the CIP / Risk Rating Process However, these will be monitored per the CIP / Risk Rating Process

Yes

Yes

Moderate

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

3 2 2

Satisfactory

Limited

Summary of Risk Ratings: Stable The new CCO conducted an assessment of the CIP / Risk Rating process, and enhancements have been made that will be implemented in December 2023. The Bank does not have a high number of "high" risk clients, maintains a process for oversight of large dollar amount transactions, and reviews risky profiles on a regular basis. BLOCKED TRANSACTIONS Yes/No or N/A Comments and description of mitigating controls Does the bank have written policies, procedures and processes to block transactions that: - Are by or on behalf of a blocked individual or entity? - Are to or go through a blocked entity? - Are in connection with a transaction in which a blocked individual or entity has an interest? Yes Does the bank properly manage and track all blocked funds, the ownership of those funds, and interest paid on those funds? - Total amounts blocked, including interest, must be reported to OFAC Yes

Limited

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

2 2 2

Satisfactory

Limited

Summary of Risk Ratings:

Stable

Within the BSA / AML Policy, and Bank leaders will engage CCO in the event this occurs.

PROHIBITED TRANSACTIONS

Yes/No or N/A

Comments and description of mitigating controls