BSA/AML Examiner School Case Study

Internal Use Only

The Bank must maintain a record of each cashier’s check, purchased for $3,000 or more in cash. • Name of purchaser; physical address of purchasers; • Social security number of purchaser or alien identification number; • Date of birth of purchaser; • Date of purchase; type(s) of instrument purchased; • Amount in dollars of each of the instrument(s) purchased; • Serial number(s) of the instrument(s) purchased; • Description of document or method used to verify the name and address of the purchaser. Note: Keep in mind that most of these items can be obtained from the customer's account at the Bank. However, tellers are still encouraged to obtain the customer's ID to verify the above items. The Bank does not sell any monetary instrument to non-customers. You need to make sure that the monetary (MIL) screen from FIS System is properly completed all required information is obtained BEFORE the purchaser leaves the Bank. If the purchaser cannot provide the required information at the time of the transaction or through the Bank's own previously verified records, the transaction is to be refused. Erroneous information on the monetary log requiring correction or completion will be immediately telephoned to the affected branch by the BSA/OFAC Officer. The branch is responsible for immediately revising and resubmitting the corrected monetary log. XVI. Funds Transfer Recordkeeping Policy and Procedures Overview It is the policy of the Bank to comply with statutory and regulatory requirements for funds transfers. BSA covers both domestic and foreign transactions and is intended to aid in combating drug trafficking and organized crime. The Bank is required to maintain certain records on funds transfers of more than $3,000. The Bank is required to obtain and retain either the original, microfilm, or other copy or electronic record of the following information relating to a payment order for a funds transfer of $3,000 or more. The BSA recordkeeping requirements vary based upon the rote of a bank with respect to the funds transfer. All records must be maintained for 5 years. Note: Incoming and outgoing wire transfers should only be processed for established customers of AJ&R Bank. Procedures have been set to adhere with the following: Recordkeeping requirements The BSA rule requires each bank involved in funds transfers to obtain and maintain certain information in connection with funds transfers of $3,000 or more. The information required to be obtained and maintained depends on the Bank's role in the particular funds transfer (originator's bank, intermediary bank, or beneficiary's bank). The requirement may vary depending on whether an originator or beneficiary is an established customer of the Bank and whether payment order is made in person or otherwise.

For Training Purposes Only

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