BSA/AML Examiner School - Case Study Oct 2023

LCB12/15

Internal Controls Checklist 22.3: Non-Governmental Organizations and Charities

Yes No

N/A

Are the institution's policies, procedures, and processes related to NGOs adequate, given the institution's NGOs accounts 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 high risk NGO accounts? Is the institution's system for monitoring NGO 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 did not provide a list of NGOs and Charities. Review of the Bank's business accounts indicated that the Bank has a small number of accounts for churches and local charities.

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