BSA/AML Examiner School - Case Study Oct 2023

LC8 12/15

Internal Controls Checklist 10.1: Funds Transfers

Yes No

N/A

Does an adequate audit trail of funds transfer activities exist?

Y

Is the volume of wire transfer activity appropriate given the institution's size, location, and nature of customer account relationships? Is there adequate separation of duties or are there adequate compensating controls to ensure proper authorization for sending and receipt of transfers, and correct posting to accounts? Obtain a sample of transfers involving currency received or dispersed in a funds transfer that exceeds $10,000. Does the institution file Currency Transaction Reports (CTRs) when currency is received or dispersed in a funds transfer that exceeds $10,000? 31 CFR 1010.311 If the financial institution sends or receives funds transfers to or from institutions in other countries, especially those with strict privacy and secrecy laws, does the institution have policies, procedures, and processes to determine whether amounts, the frequency of the transfer, and countries of origin or destination are consistent with the nature of the :business or occupation of the customer? Review the institution's procedures and processes related to funds transfers. Are they adequate given the institution's funds transfer activities and the risks they present? Are the institution's controls adequate to reasonably protect the financial institution from money laundering and terrorist financing?

Y

Y

NA

Y

Y

Y

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