BSA/AML Examiner Training Series 2

Internal Use Only

Internal Controls

Review of the bank’s written policies, procedures, and processes.

Board of Directors ultimately responsible.

Designed to limit and control risks and to achieve compliance. Commensurate with the size, structure, risks, and complexity of the bank.

Internal Use Only

Internal Controls

Identify banking operations more

Inform the board of deficiencies and of SARs filed.

Identify a person responsible for BSA/AML compliance.

Meet all regulatory recordkeeping and reporting requirements.

Provide for program continuity.

vulnerable to abuse by money launderers and criminals.

Provide sufficient controls and monitoring systems for timely reporting of suspicious activity.

Provide sufficient controls and systems for filing CTRs and CTR exemptions.

Implement risk-based CDD policies, procedures, and processes.

Identify reportable transactions.

Provide for dual controls.

Train employees to be aware of their responsibilities under the BSA regulations and internal policy guidelines.

Incorporate BSA compliance into job descriptions and performance evaluations.

Provide for adequate supervision of employees.

The above list is not designed to be all-inclusive and should be tailored to reflect the bank’s BSA/AML risk profile.