BSA/AML Examiner School Case Study

Internal Use Only

• Identity theft • Misuse of position or self-dealing • Mortgage loan fraud • Mysterious disappearance

• Terrorist financing • Wire transfer fraud

Note: A SAR does not have to be filed for a robbery or a burglary that is reported to the appropriate law enforcement authorities or for lost, missing, counterfeit or stolen securities that are reported pursuant to the lost and stolen securities program. XIII. Currency Transaction Reporting (CTR) Policy and Procedures Overview It is the policy of the Bank to comply with all requirements of the Bank Secrecy Act and all regulations of the Department of Treasury and the Internal Revenue Service (IRS). The requirement governs all physical, individual or aggregate, transfers of coin or currency, U.S. or foreign and certain monetary instruments with a value of more than $10,000. Proper procedures have been implemented to provide operational safeguards to assure that all required reporting occurs. A CTR form must be completed if all cash transactions by one person totals more than $10,000 in one banking day or cash transactions aggregate to more than $10,000. The Bank utilizes PIS System to generate the CTR forms. The system will produce a CTR when the transaction(s) received are MORE Than $10,000 or have aggregated to MORE than $10,000. It is the responsibility of the staff member processing a transaction to obtain the required information prior to completing the transaction. Not only is the identity of the person conducting the transaction required, but also the identity of any person or entity on whose behalf the transaction is being conducted. CTR Verification The CTRs will be reviewed for accuracy and completeness by the BSA Officer before final submission to the IRS reporting center. However, the employee processing the transaction and their supervisor are ultimately responsible for the general accuracy and completeness of the form. An incomplete CTR will be returned to the branch for immediate revision and resubmission to the BSAJOFAC Officer. Note: All Bank employees must be aware that the proper completion of CTRs is considered a serious matter. Erroneous or incomplete information places the Bank and the individuals preparing the form in technical violation of the Act. Civil and criminal penalties can be imposed on the Bank and individual employees if either violates the Bank Secrecy Act. Filing Timeframes and Record Retention Requirements All completed CTRs are filed with FinCEN within 15 days after the date of the transaction. Copies of CTRs must be retained for 5 years from the date of the report. Note: Erroneous information on the CTR requiring correction or completion will be immediately telephoned to the affected branch by the BSA/OFAC Officer. The incomplete CTR will be returned to the branch for immediate revision and resubmission to the BSA/OFAC Officer.

For Training Purposes Only

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