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

SARs Two (100%) Suspicious Activity Reports (SARs) were reviewed during this follow-up review. Technical errors were noted with both SARs and one was filed after the 30-day

filing requirement. CTR Exemptions

The Bank's two CTR reporting exemptions were addressed by the FDIC during its 2014 examination and by BBC during its 2014 independent test. The required revisions were not completed until April 27, 2015. The length of time between notification of issues with these exemptions and the completion of the revisions is a concern. In addition, based on a review of the amended submissions to FinCEN, the same errors addressed previously were still present. It was recommended that the BSA Officer Collins correct these forms and again re-file them with FinCEN. Information Sharing 314(a) Although BSA Officer was added to the call report to receive the search requests, she was not fully trained on how to complete search requests. BSC reviewed the search instructions with the BSA Officer during this review to ensure she has a complete understanding of the requirements and process. At this time, Kim Chancy and Tom McVey continue to complete the searches. It is recommended that BSA Officer Collins and Assistant BSA Officer Grant complete the 314(a) search requests and verifications going forward. Recommendation It is recommended that the Bank address the issues noted above, as wel l as any i tems outstanding from previous reviews and examinations, as soon as possible.

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