BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Internal Controls Checklist 6.1: Suspicious Activity Report

Review of Policies Procedures, and Processes

Yes No

N/A

Answer the following questions based on a review of the institution's policies, procedures, and processes for identifying, researching, and reporting suspicious activity. Do they include the following: • Lines of communication for the referral of unusual activity to appropriate personnel? • Designation of individual(s) responsible for identifying, researching, and reporting suspicious activities? • Procedures to ensure the timely generation of, review of, and response to reports used to identify unusual activities? • Procedures for reviewing and evaluating the transaction activity of subjects included in law enforcement requests (e.g., criminal subpoenas, 314(a) requests, or national security letters (NSLs)) for suspicious activity? • Monitoring systems used to identify unusual activity?

Y

Y

Y

Y

Y

3 0