BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Checklist 3.1: BSA Compliance Program General Requirements (cont.)

Yes No

N/A

• Penalties for noncompliance with internal policies and regulatory requirements? 12 CFR 21.21(c)(4); 12 CFR 163.177(c)(4); 12 CFR 208.63(c)(4); 12 CFR 326.8(c)(4); 12 CFR 390.354(c)(4) Based on interviews with personnel whose jobs are affected by BSA (tellers, fund transfer personnel, internal auditors, loan personnel, etc.), do they appear knowledgeable regarding the BSA requirements affecting their position? 12 CFR 21.21(c)(4); 12 CFR 163.177(c)(4); 12 CFR 208.63(c)(4); 12 CFR 326.8(c)(4); 12 CFR 390.354(c)(4); 12 CFR 748.2(e)(4)

Y

Y

Comments: Annual Employee Training — Annual training for all Bank employees was held January 23, 2015. XXXX from BBC presented the training. In addition, employees received on-line training through "Digital University". It appears that all employees received training. To further enhance training, it is recommended that all employees receive a copy of the BSA/AML Policy and document receipt and understanding of the Policy. Board of Directors Training — The Board of Directors received formal BSA/AML training presented by BBC on January 23, 2015. New Employee Training — The Bank hired seven new employees from February through December 2015. Four employees have not received training as of this review: President/CEO, Loan Officer; Administrative Assistant and Teller. Lack of training could present greater BSA/AML risk to the Bank. Recommendation — It is recommended that these individuals receive BSA/AML training as soon as possible. In addition, the Bank's BSA/AML Policy should be revised to include a timeframe (within 30 days from hire date) for new employees to complete training on the Bank's BSA/AML/CIP policies and procedures. One line training for new employees should be completed within 90 days of date of hire. BSA Officer & Personnel Training — BSA Officer completed the following: • Pegasus 2015 "BSA/AML Compliance Management" seminar January 26, 2015 • KBA/Pegasus "BSA Compliance School" June 8-9, 2015. Assistant BSA officer attended:

• KBA/Pegasus "BSA Compliance School" June 8-9, 2015.

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