BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Internal Controls Checklist 17.1: Electronic Banking

Electronic Bankin

Yes No

N/A

Based on a review of procedures used to conduct due diligence on customers opening accounts (loan or deposit) through electronic means, does the institution obtain proper verification of customer identity and source of funds used to open deposit accounts? Has management established and followed procedures to review transaction activity through electronic banking products for possible money laundering and suspicious activity?

NA

Y

Yes No

N/A

Are the institution's policies, procedures, and processes related to e banking, including remote deposit capture, adequate, given the financial institution's e-banking activities and the risks they present? Based on a review of management information systems (MIS) and internal risk rating factors, does the institution effectively identify and monitor high-risk e banking activities? is the institution's system for monitoring and reporting e-banking, including remote deposit capture, for suspicious activities adequate given the financial institution's size, complexity, location, and types of customer relationships?

Y

Y

y

Comments: On-line account opening - Request list responses indicate that the Bank does not open accounts on-line. On-line Banking — The Bank offers on-line banking services through FIS. Customers must complete an on line application to access this service. Services offered are bill payment, interbank transfers, balance inquiries, and statement access. Bill Payments — The Bank offers bill payment services through FIS. To access this service, the customer must apply and be a current on-line banking customer. Mobile Banking — Request list responses indicate that the Bank does not offer mobile banking. Telephone Banking - The Bank offers telephone banking. The service is automatically set up when the customer opens an account. The Customer must call a specific number and follow the prompts. A four digit PIN is required. Debit Cards - The Bank offers MasterCard® debit cards. Limits are set for ATM withdrawals at $500 and Point of Sale (POS) transactions at $1,000. ATM Cards — Request list responses indicate that the Bank does not issue ATM cards.

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