BSA/AML Examiner School - Case Study Oct 2023

LCB12/15

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

Yes

No

N/A

Does the institution file Form 105 (CMIR) for each shipment of currency or other monetary instruments in excess of $10,000 out of or into the United States on behalf of the institution (not its customers), except via common carrier, by, or to the institution? 31 CFR 1010.340(a)

NA

Comments: Program Continuity — In the event that the BSA Officer cannot perform her duties, BSA Assistant/Compliance Officer can perform some of the daily duties. The Bank is encouraged to fully train any employee identified as back up to the BSA Officer. Electronic Filing with FinCEN — The Bank currently files all the required forms using the FinCEN filing system. Job descriptions — The Bank does not currently use job descriptions. Review of the Bank's policies indicated that employees are responsible for compliance with BSA/AML and OFAC and any consequences for non- compliance. Report of International Transportation of Currency or Monetary Instruments (Form 105) —Request list responses indicate that the Bank has not had any instances for which it needed to file Form 105.

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