BSA/AML Student Exercises Dec. 2022

LCB12/15

Checklist 3.1: BSA Compliance Program General Requirements (cont.)

Yes No

N/A

Do the institution's program and monitoring procedures provide for identification of reportable transactions and accurately electronically file all required reports, including SARs, currency transaction reports (CTRs), and CTR exemptions. Are all appropriate BSA forms filed electronically using FinCEN's BSA e-file system. Do the institution's program and procedures provide for dual controls and the segregation of duties? (For example, employees who input the information for the forms (e.g., SARs, CTRs, and CTR exemptions) should not also be responsible for reviewing the reports.) Does the institution provide for adequate supervision of employees who handle currency transactions, complete reports, grant exemptions, monitor for suspicious activity, or engage in any other activity covered by the BSA and its implementing regulations? Does the institution incorporate BSA compliance into job descriptions and performance evaluations of appropriate personnel? Does the institution file a CTR for each deposit, withdrawal, exchange of currency, or other payment or transfer by, through, or to the financial institution that involves more than $10,000 in currency in any one business day for nonexempt customers? 31 CFR 1010.311(b)(1)

Y

Y

Y

Y

*y

Y

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