BSA-AML Examiner School Case Study eBook

Trade Finance Activities

No _X

Yes

If yes, describe:

No X

Yes

Private Banking

If yes, describe:

No X

Yes

Trust and Asset Management Services

If yes, describe:

Yes __ No X describe:

If yes,

Insurance Services

Please check one of the following for each category: Low Moderate X

High

Comments

No electronic banking (e- banking) or the web site is informational/non- transactional.

The bank has e-banking and offers limited products and services (i.e., internal account transfers and e-bill payment).

The bank offers a wide array of e-banking products and services (i.e., account transfers, e-bill payment or accounts opened via the Internet).

Customers using online/mobile banking can make internal and external transfers and use bill pay. See bill pay above. Customers with mobile banking can make mobile deposits. These are reviewed by bank personnel. New accounts cannot be opened through online banking. Mortgage loan applications are taken online through a secure server. A mortgage loan is not opened until all CIP information is verified.

Low X

Moderate

High

Comments

No foreign correspondent financial institution accounts. The bank does not engage in pouch activities, offer special-use accounts, or offer payable through accounts (PTAs), or provide U.S. dollar draft services.

The bank has a few foreign correspondent financial institution accounts, but typically with financial institutions with adequate AML policies and procedures from low-risk countries, and minimal pouch activities, special-use accounts, PTAs, or U.S. dollar draft services.

The bank maintains a large number of foreign correspondent financial institution accounts with financial institutions with inadequate AML policies and procedures from, particularly located in high-risk jurisdictions, or offers substantial pouch activities, special-use accounts, PTAs, or U.S. dollar draft services.

For Training Purposes Only