BSA/AML Examiner School - Case Study Oct 2023

BSA/AML EXAMINER SCHOOL Customer Identification Program

You have developed a sample size for your transaction testing. You carefully picked out 32 accounts from different locations and opened at different time periods. Management has provided the customer files on the 32 accounts that you sampled. Consider the following questions when reviewing the CIP documents.

1) Did management obtain all the information as required for CIP purposes?

2) Did management follow risk-rating procedures in the BSA Policy?

3) Has management appropriately checked customers against the OFAC list prior to opening the account?

4) Based on your review, did you identify any exceptions?

5) Do you think the bank has appropriate CIP program procedures?

6) Keep a list of any questions you have for the BSA Officer.