BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Checklist 6.1: Suspicious Activity Report (cont.)

Review of the Institution's Suspicious Activity Monitoriine Systems

Yes No

N/A

Do the institution's monitoring systems adequately fit into its overall suspicious activity monitoring and reporting process? Complete the appropriate manual/automated monitoring review procedures that follow. When evaluating the effectiveness of the monitoring systems, consider the institution's overall risk profile (high-risk products, services, customers, entities, and geographic locations), volume of transactions, and adequacy of staffing. If the institution uses manual transaction monitoring, answer the following: • Based on a review of the institution's transaction monitoring reports, do the reports capture all areas that pose money laundering and terrorist financing risks? • Do the institution's monitoring systems use reasonable filtering criteria whose programming has been independently verified? • Do the monitoring systems generate accurate reports at a reasonable frequency? If the institution uses automated account monitoring, identify the types of customers, products, and services that are included within the automated account monitoring system and the system's methodology for establishing and applying expected activity or profile filtering criteria and for generating monitoring reports.

Y

Y

Y

Y

• Are the system's filtering criteria reasonable?

NA

3 2