BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

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

Internal Controls

N/A

Yes No

Does the BSA/AML program identify high-risk banking operations (products, services, customers, and geographic locations, including compliance with special measures as required by section 311 of the USA PATRIOT Act), provide for periodic updates to the bank's risk profile, and provide for a BSA/AML compliance program tailored to manage risks? Does the BSA/AML program provide for continuity, despite changes in management or employee composition or structure? Does the institution's compliance program include procedural guidelines for the detection, prevention, and reporting of suspicious transactions related to money laundering activities? These should include procedures to infonn the board of directors (or a committee) and senior management of compliance initiatives, identified compliance deficiencies, suspicious activity reports (SARs) filed and corrective action taken. 12 CFR 21.21(c)(1); 12 CFR 163.177(c)(1); 12 CFR 208.63(c)(1); 12 CFR 326.8(c)(1); 12 CFR 390.354(c)(1); 12 CFR 748.1(c)(1) SAR filing requirements at 12 CFR 21.11; 12 CFR 163.180; 12 CFR 208.62, 12 CFR 353; 12 CFR 390.355; 12 CFR 748.1(c)(4) Does the institution's program reach all operations that are affected by BSA (retail, trust, private banking, commercial, wire transfer, teller, discount brokerage, etc.)? 12 CFR 21.21(c)(1); 12 CFR 208.63(c)(1); 12 CFR 326.8(c)(1); 12 CFR 390.354(c)1; 12 CFR 163.177(c)(1); 12 CFR 748.2(c)(1)

Y

Y

.

Y

Y

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