Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual

BSA/AML Examination Procedures

Procedure

Comments

• Review account statements and, as necessary, specific transaction details for:  Expected transactions with actual activity.  Holdings in excess of the customer’s net worth.  Irregular trading patterns (e.g., incoming funds transfers to purchase securities followed by delivery of securities to another custodian shortly thereafter). • Determine whether actual activity is consistent with the nature of the customer’s business and the stated purpose of the account. Identify any unusual or suspicious activity. 8. On the basis of examination procedures completed, including transaction testing, form a conclusion about the adequacy of policies, procedures, and processes associated with NDIP sales activities.

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