BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Transaction Testing Checklist 10.3: Funds Transfer Recordkeeping

Sample Date

Incoming Reviewed/Total//0

Outgoing Reviewed/Total/%

1 September 2015 2 October 2015 3 November 2015

0/0/0%

3/3/100% 2/3/100% 5/5/100%

3/3/100% 1/1/100% 4/4/100%

Total

10/10/100%

Information Retrievabili

1 2 3

Are the retained records retrievable by the name of originator (for originated transfers) and name of beneficiary (for received transfers), and, if they are established customers,

Y Y

Y

by account number? 31 CFR 1020.410(a)(4)

Comments: The Bank maintains a spreadsheet to identify all wires.

7 7