BSA-AML Examiner School Case Study eBook

Internal Use Only

Customer Identification Program

Moderate Moderate Moderate Moderate Moderate Moderate Moderate

Satisfactory Satisfactory Satisfactory Satisfactory Satisfactory Satisfactory Satisfactory Satisfactory Satisfactory

Limited Limited Limited Limited Limited Limited Limited Limited Limited

Stable Stable Stable Stable Stable Stable Stable Stable Stable

Customer Due Diligence

Beneficial Ownership - Legal Entities Suspicious Activity Reporting Currency Transaction Reporting Transaction of Exempt Persons

Information Sharing

Purchase and Sale - Monetary Instruments

Limited Limited

Funds Transfers

Foreign Correspondent Accounts Private Banking (Non-U.S. Persons)

- -

- -

- -

- -

Special Measures

Limited

Satisfactory

Limited

Stable

Reports of Foreign Financial Accounts

-

-

-

-

Reports of International Transportation of Currency or Monetary Instruments

-

-

-

-

Miscellaneous (Add more info if needed)

-

-

-

-

Overall BSA/AML Risk Ratings (average)

Moderate

Satisfactory

Limited

Stable OFAC Regulatory Requirements

Inherent Risk

Trend (↑,→,↓)

Control Rating Residual Risk

Risk Category

Comments

Geographic Location & Bank Info

Limited Limited

Satisfactory Satisfactory Satisfactory Satisfactory Satisfactory Satisfactory Satisfactory

Limited Limited Limited Limited Limited Limited Limited

Stable Stable Stable Stable Stable

Products Services

Moderate Moderate

Customers & Entities Blocked Transactions Prohibited Transactions

Limited Limited Limited

-

OFAC Reporting

Stable

Miscellaneous (Add more info if needed)

-

-

-

-

Overall OFAC Risk Ratings (average)

Limited

Satisfactory

Limited

Stable