BSA-AML Examiner School Case Study eBook

Internal Use Only

Does the bank have written policies, procedures and processes to reject transactions if the underlying transaction may be prohibited but there is no blockable interest in the transaction (i.e. the transaction should not be accepted, but there is no OFAC requirement to block the assets)?

Yes

Limited

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

2 2 2

Satisfactory

Limited

Summary of Risk Ratings:

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

OFAC REPORTING

Yes/No or N/A

Comments and description of mitigating controls

Does the bank report all blockings to OFAC within 10 business days of the occurrence and annually by September 30th concerning those assets blocked (as of June 30th)? Does the bank place blocked funds into a separate blocked account once the blocking occurs? Does the bank maintain an accurate record of each rejected transaction for at least five years after the date of the transaction?

Yes

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

Within the BSA / AML Policy, and Bank leaders will engage CCO in the event this occurs. MISCELLANEOUS (CUSTOMIZE TO YOUR BANKS NEEDS)

Yes/No or N/A

Comments and description of mitigating controls

add optional risks here add optional risks here add optional risks here add optional risks here add optional risks here

- - -

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

Summary of Risk Ratings:

Assign Overall Trend → [enter reason(s) for the determination of the residual risk rating based on applicable risk factors such as weaknesses in policies, procedures or controls, recent exam or review findings, transaction volume, customer risk, regulatory risk etc.]

2.29

Limited

Overall Inherent Risk →

Overall Risk Ratings

2.00 2.00

Satisfactory

Overall strength of Controls →

Limited

Overall Residual Risk → Assign overall Trend →

Stable The Bank's overall OFAC Program is stable and strong. As of July 2023, the bank approved an enhanced BSA Policy and appointed a new CCO and BSA Officer. The new BSA Officer has subsequently reviewed and enhanced additional OFAC processes and procedures across the Bank, established tracking and reporting, and provided additional training to impacted staff. BSA/AML/OFAC Risk Assessment Automated Rollup BSA/AML Regulatory Requirements Risk Category Inherent Risk Control Rating Residual Risk Trend (↑,→,↓) Comments