BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Internal Controls Checklist 11.8: Nonresident Aliens and Foreign Individuals

Yes No

N/A

Based on a review of the institution's policies, procedures, and processes related to NRA and foreign individual accounts, are the policies, procedures, and processes adequate given the institution's nonresident alien and foreign individual activities and the risks they represent? From a review of management information systems (MISs) and internal risk rating factors, does the institution effectively identify and monitor high-risk NRA and foreign individual accounts? Are the institution's system of monitoring NRA and foreign individual accounts for suspicious activities and for reporting of suspicious activities adequate, based on: • The complexity of the bank's NRA and foreign individual relationships?

Y

Y

NA

• The types of products used by NRAs and foreign individuals?

NA

The home countries of the NRAs?

•

NA

• The source of funds and wealth for NRAs and foreign individuals?

NA

Comments: The request list indicates that the Bank does not have any NRA and foreign individual accounts.

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