BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Internal Controls Checklist 18.1: Brokered Deposits

Yes No

N/A

Are the institution's policies, procedures, and processes related to deposit broker activities adequate given the institution's deposit broker activities and the risks they present? Based on a review of management information systems (MIS) and internal risk rating factors, does the institution effectively identify and monitor deposit broker relationships, particularly those that pose a high risk for money laundering? Is the institution's system for monitoring deposit broker relationships for suspicious activities and for reporting suspicious activities adequate, given the bank's size, complexity, location, and types of customer relationships?

Y

Y

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Comments: The Bank currently has nine brokered accounts totaling $2,232,000. According to President/CEO, these accounts will be phased out as they mature. 5 6