BSA/AML Examiner School - Case Study Oct 2023

AJ&R BANK & TRUST BANK SECRECY ACT/ANTI-MONEY LAUNDERING INTERIM REVIEW REPORT APRIL 2015 REVISED JULY 17, 2015

Training Documentation The Bank's existing training records do not appear to include all BSA related training. For example, based on information provided, training specific to the Travel Rule does not appear to have been conducted. As was recommended in the September 2014 report, any training related to BSA, whether formal or informal, should be appropriately documented. In addition, a formal training schedule should be developed. CTRs It appears that all of the Currency Transaction Reports (CTRs) noted as containing errors at BBC's September 2014 independent test were corrected and re-filed with FinCEN. BBC's review of CTRs filed since September 2014 determined that all were completed within the 15 calendar day requirement. Minor technical errors were noted with the completion of certain fields; these have been addressed with BSA Officer Collins. The Bank's current practice is for either BSA Officer or her Assistant to complete the CTR; the other individual then reviews it prior to submission. Wire Transfers It was noted that documentation for wire transfers has improved. The Bank is now using a wire transfer spreadsheet to record all wire transactions. Several areas need to be added to this spreadsheet such as incoming beneficiary account number, wire originator, originating bank, outgoing originator account number, beneficiary, and beneficiary bank. An outgoing wire transfer authorization form has been created to ensure that all information required to process the wire transfer is documented. The Bank is encouraged to ensure compliance with these documentation requirements through on-going training and occasional reviews. Documentation of training for applicable staff on "Travel Rule" requirements was not presented. It does not appear that such training occurred. CIP and CDD CIP documentation for all new accounts is now being reviewed by BSA Officer Collins to ensure compliance with requirements. Information that is not obtained at account opening is being noted, and the individual who opened the account is responsible for addressing any issues noted. The CIP/CDD forms presented for BBC's review at this follow-up were copies of the examples provided at the September 2014 independent test. These forms had not been modified to reflect actual Bank policy or procedures. Documentation of CIP training for the staff was not presented for review at this follow-up. BBC was unable to determine whether this training occurred.

For Training Purposes Only

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