BSA/AML Examiner School - Case Study Oct 2023

• Update Suspicious Activity Monitoring Procedures to align with actual practices. • Perform research and work with the BSA/AML software vendor to more accurately use the model to aid in monitoring for suspicious activity. Such activities would likely include, but not be limited to, a review of applicable scenarios, performance of above/below the line testing, and an outcomes analysis to validate movement of alerts to cases and SAR filings. This information can assist the bank in measuring the success of their scenario parameters as well as benefits of utilizing the model for monitoring. • Ensure annual reviews of CTR exempt customers are completed appropriately, and that documentation of continued eligibility is included in such. After further review of the bank’s risk assessment (which only lists 4 MSBs), you decide to have an interview with the BSA Officer regarding MSBs and higher risk activity. Notes from Examiner Interview with the BSA Officer: • She hasn’t had time to update the risk assessment yet, but it’s on her calendar for this month. • She is in the process of putting together all the recommendations and managements responses from prior examinations and audits. • EDD reviews are in process. • She lets you know that the bank has a few MSBs, but they have been customers for years. A few that come to her mind are: o Tienda Mia, Salamka Market Inc., and Tienda Mi Amigo – MSBs that cash checks o Juan Ortiz is an MSB that is an agent for wire services

Group Discussion Based on the information provided above and the FinCEN data: 1. What areas of concern would you have if you were conducting the BSA exam? 2. Would you cite any violations? If so, what?

Updated: 11/15/2022

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