BSA/AML Examiner School - Case Study Oct 2023

LCB12/15

Internal Controls Checklist 22.1: Non-Bank Financial Institutions

Yes No

N/A

Are the institution's policies, procedures, and processes related to NBFI accounts adequate, given the institution's NBFI activities and the risks they present? Based on a review of management information systems (MIS) and internal risk rating factors, does the institution effectively identify and monitor NBFI accounts? Is the institution's system for NBFI accounts for suspicious activities, and for reporting suspicious activities, adequate given the institution's size, complexity, location, and types of customer relationships?

Y

Y

Y

Comments: The Bank provided a list of two NBFIs. No accounts are considered Money Services Businesses (MSBs).

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