BSA/AML Examiner School - Case Study Oct 2023

LCB12/15

Transaction Testing Checklist 22.7: Professional Service Providers

Name of Professional Service Provider

Account Open Date

1 XXXX

06/17/2015

1

Y

Is the account opening documentation consistent with the institution's CIP procedures?

Y

Does the account opening documentation adequate to form a reasonable belief regarding the identity of the accountholder? Is the institution's ongoing due diligence adequate given the risk? (See Chapter 4 "Customer Due Diligence.")

Y

Y

Is the actual activity consistent with the nature of the customer's business?

,-, Is the actual activity in the account consistent with the expected transactions regarding the account? Y If any activity appears to be suspicious, review the decision whether or not to file a SAR, using the "SAR Decision Process" checklist in Chapter 5. NA Comments: Account statements for September through November 2015 were reviewed. Activity on the accounts appears normal; no unusual or suspicious activity was identified.

8 4