BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Checklist 3.1: BSA Compliance Program General Requirements (cont.)

Anti-Money Laundering Program

Yes No

N/A

Do the institution's anti-money laundering policies address:

The various types of money laundering?

•

Y

• Compliance with BSA and related anti-money laundering laws and regulations?

Y

A customer due diligence program?

•

Y

• Identifying high-risk activities, businesses, and foreign countries (those commonly associated with money laundering)? Do the institution's anti-money laundering policies extend to all of its operations? Does the institution have a high level of internal controls to minimize the risk of money laundering?

Y

Y

Y

Comments: Various Types of Money Laundering — The Bank's BSA/AML Policy addresses various types of money laundering and describes the three stages of money laundering. High Intensive Drug Trafficking Area (HIDTA) — Request list responses indicate that the Bank is not conducting business within HIDTAs. High Intensity Financial Crimes Area (HIFCA) . - Request list responses indicate that the Bank is not conducting business within HIFCAs.

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