BSA-AML Examiner School Case Study eBook

OFAC Risk Assessment Conclusion: TS&J Bank’s overall OFAC risk is considered low to moderate. All personnel have been trained on OFAC. TS&J has policies and procedures in place to identify if any new or existing customer is on the OFAC list. See TS&J’s OFAC Procedures for additional detail. Other Risk Factors: Describe any other AML/BSA risks: TS&J has a well-known stable customer base and procedures in place to identify new customers and check them against government lists. Several reports are monitored on a regular basis to identify any activity that would be considered suspicious. Higher risk customers are identified and monitored. There is very little movement of funds from customer accounts to international banks. There has been a minimal amount of activity that has resulted in filing CTR’s or SAR’s during the past year. BSA/AML/OFAC training is taken by all employees. The past internal BSA Audits and regulatory examinations have resulted in minimal findings. The senior management is stable and trained on BSA. Conclusion - Overall AML/BSA Risk Assessment Rating: Low_X Moderate High Comments Low risk of being used in money laundering or terrorist financing Moderate risk of being used in money laundering or terrorist financing High risk of being used in money laundering or terrorist financing See comments above.

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