BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

and • Any transaction conducted by or on behalf of a named suspect, or any transmittal of funds conducted in which a named suspect was either the transmittor or the recipient, during the preceding six months that is contained in the wire transfer log, the log of purchase/sales of monetary instruments, and any other transaction records that can be searched electronically? 31 CFR 1010.520(b)(2)(i) If, as a result of the searches, the financial institution did find an account or transaction with any of the individuals or entities, did the institution report the following information to FinCEN, within the time frame specified in the request: • The name of the individual, entity, or organization; • The number of each account, or in the case of a transaction, the date and type of each transaction; and • Any Social Security number, taxpayer identification number, passport number, date of birth, address, or other similar identifying information provided by the individual, entity, or organization when each account was opened or each If, as a result of the searches, the financial institution did find an account or transaction with any of the individuals or entities, based on a review of the financial institution's documentation (including account analysis), was the institution's determination to file or not file a SAR was warranted? Note: Financial institutions are not required to file SARs solely on the basis of a match with a named subject; instead, account activity should be considered in determining whether a SAR is warranted. transaction was conducted? 31 CFR 1010.520(b)(2)(ii)

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