BSA/AML Examiner School - Case Study Oct 2023

BANK SECRECY ACT REQUEST LIST

Internal Use Only

Institution:

AJ & R Bank & Trust

Examination Date: July 1, 2016 Items marked as "Onsite" should be retained in your offices for examiner review during the on-site portion of the examination. The remaining items should be furnished to examiners by June 24, 2016. For documents that are too long for convenient copying, please provide originals for examiner review at the institution. Clearly identify all items that should be returned to bank personnel.

BANK SECRECY ACT Item # Onsite

Item Description

20.01

Name and title of the designated BSA/AML compliance officer and, if different, the name and title of the person responsible for monitoring OFAC compliance. If a complex reporting structure, provide organizational charts showing direct and indirect reporting lines. BSA/AML/OFAC policies and procedures to comply with all reporting and recordkeeping requirements, including suspicious activity, customer due diligence, and CIP. Correspondence with and subpoenas from the U.S. Treasury (Office of the Secretary and Department of the Treasury, Internal Revenue Service, FinCEN, and OFAC) or law enforcement authorities since the previous BSA/AML examination. Audit schedule and independent audits/tests performed since the previous BSA/AML/OFAC examination. Include the scope, management's responses, and access to the workpapers. BSA/OFAC Risk Assessment of products, services, customers, and geographic locations. Also, provide a list of high-risk account holders. X Summary of training program (e.g., materials used for training since the previous BSA/AML examination). X BSA/AML training schedule with dates, attendees, and topics. A list of persons in positions for which the bank typically requires BSA/AML training but who did not participate in the training. X Account opening forms (e.g., for loans, deposits, or other accounts) used to document CIP/Customer Due Diligence information. List of new accounts (opened for new customers of the bank) covering all product lines (including accounts opened by third parties) from 09/01/2015to 07/08/2016. X X List of accounts without taxpayer identification numbers (TINs). X

20.02

20.03

20.04

20.05

20.06

20.07

21.01

21.02

21.03

21.04

X

List of Money Service Business customers.

21.05

X

List of all high risk customers of the bank.

FDIC

1

05/27/2016