BSA/AML Examiner School - Case Study Oct 2023

LCB 12115

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

BSA Compliance Officer

Yes No

N/A

Has the board of directors designated a person or team responsible for the overall BSA/AML compliance program? Does the BSA compliance officer have the necessary authority and resources to effectively execute all duties? Are the BSA compliance officer and his or her staff competent to carry out the duties assigned them, and no conflicts of interest exist? Is the BSA compliance area is sufficiently staffed for the bank's overall risk level (based on products, services, customers, and geographic locations), size, and BSA/AML compliance needs, and is it given adequate time and resources to execute all duties? Do the board of directors and senior management receive adequate reports on BSA/AML compliance?

Y

Y

Y

y

*y

Comments: BSA Officer Appointment — The Board of Directors reappointed XXXX as BSA Officer at the May 22, 2015 Board meeting. Reporting to the Board — The Board of Directors is ultimately responsible for ensuring that a bank maintains an effective BSA/AML internal control structure, including suspicious activity monitoring and reporting. Comprehensive reporting is an essential component of ensuring that this internal control structure is maintained and accurate BSA/AML compliance decisions concerning the Bank are made by the Board. The Board currently receives BSA/AML reports from the BSA Officer on a monthly basis. The report consists of only information regarding new accounts opened, CTRs and SARs filed, and 314 (a) report searches. The Board of Directors should receive information more comprehensive information including any review of compliance areas and the results, exam or audit exceptions and their resolution, training, comparison of current and prior year CTR and SAR filings, wire transfer activity, any recent changes in BSA/AML/OFAC/CIP regulatory requirements, responses to 314(a) and OFAC searches, and information concerning recent law enforcement and judicial requests for customer information. Recommendation — It is recommended that the Bank revise the monthly report to contain the areas noted above.

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