BSA/AML Examiner School - Case Study Oct 2023

LCB12/15

Checklist 6.1: Suspicious Activity Report (cont.)

Yes No

N/A

Does the institution have a system for ensuring exception reports are responded to in a timely manner, and are utilized and maintained by appropriate parties to assist in detecting patterns of unusual activity? Does the institution have a system (automated or manual) to detect structured transactions (both cash in and cash out) that are under the $10,000 reporting threshold? Does the institution review a listing of filed CTRs to determine if the institution or any branches had significant changes in the CTRs volume or nature? Does the institution review the SARs related to money laundering it has filed to determine if the institution or any branches had significant changes in the volume or nature of SARs filed, and does the institution investigate the reasons for any change? Does the institution review cash shipment reports to determine if there are any unusual trends in the volume or composition of cash shipments? Does the institution have procedures for documentation of decisions not to file a SAR?

Y

Y

Y

NA

Y

Y

Comments: Currency Shipments — The request list response to this question was not completed. CFO was noted in our 2014 review. 3 7