BSA/AML Examiner School - Case Study Oct 2023

V. Designation of BSA Officer The Board of Directors is responsible to appoint a BSA Compliance officer on an annual basis, The Board of Directors has designated XXXX to serve as the BSA Compliance Officer (BSA/AMUOFAC Officer) all decisions made by The Board of Directors must be noted in the board minutes. The Board of Directors has granted the BSA Compliance Officer with the authority, subject to the approval and supervision of the Board of Directors and Senior Management, to develop and administer a program that provides for Bank Secrecy Act compliance and training. This includes assuming full responsibility for all Bank Secrecy Act policy statements and procedures. The BSA Compliance Officer is required to be fully knowledgeable of the BSA and all related regulations, and also understand the Bank's products, services, customers, geographic locations, and the potential money laundering and terrorist financing The Bank is required to ensure that all personnel receive training on the directives of the Bank Secrecy Act on a scheduled basis. All employees of the bank will be trained annually. Training will include regulatory requirements and the Bank's internal BSA, AML and OFAC policies, procedures and processes. The Bank's training program will provide training for all personnel whose duties require knowledge of the BSA, and the training is to be tailored to the person's specific responsibilities. Additional trainings may be via email or hard copy of the training materials. In addition, an overview of the BSA, AML and OFAC requirements are to be provided to new staff during the employee orientation. Documentation of personnel trained, and the dates of training will be maintained by the BSA Department. The BSA Compliance Officer will attend several external training sessions annually. The Board of Directors will be provided with annual training on the general BSA requirements. The BOD is required to understand the importance of BSA, AML and OFAC regulatory requirements, the ramifications of noncompliance, and the risks posed to the Bank. The BOD will be informed of changes and new developments in the BSA, its implementing regulations and directives, and the federal banking agencies' regulations. risks associated with those activities . VI. Training of all Staff Personnel High Risk Customers The account officers must identify high risk customers at account opening process and/or throughout the account relationship. High Risk customers may include regular customers, businesses, exempt customers, foreign customers or any other type of customers in the bank. All high-risk accounts will be closely monitored by the BSA Department. Customers that create a higher risk will be placed in The BSA - High Risk Customer listing maintained by the BSA Department; the listing will be updated as necessary. High risk customers will be placed in this listing after a thorough analysis on the account, and not from a label affixed to the customer's operations. It is the responsibility of the BSA Officer to validate the frequency of account monitoring by reviewing the "high risk" customer's file and subsequently revising the frequency from time to time. In addition, the BSA Officer and the SAR Committee will determine whether an account should be closed, additional monitoring required, or a SAR completed. INTERNAL CONTROLS/REGULATORY REQUIREMENTS

For Training Purposes Only

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