Introductory BSA/AML Examiner School, Atlanta, CA

Bank of Smithville USA

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Required Action: BSA Officer Marks should develop and provide training materials specifically designed for certain business lines and departments. Supporting Comment: The independent audit identified certain areas that should receive specialized BSA/AM training. These included the following business lines: Consumer Loan Specialties Group, Real Estate Specialties Group, Registered Transfer Agent, Trust, and Indirect Lending and Leasing. Training should also be developed for BSA department personnel to ensure consistency in the completion of various functions, including the handling of Verafin alerts and cases, completion of SARs, and EDD reviews. Management’s Response: BSA Officer Marks stated that specialized training for the BSA department and business lines will be completed by the end of November and December 20XX, respectively . • Supervisory Recommendation #09-20XX.06 – An ineligible Phase II exemption should be revoked, a back filing determination obtained, and any required CTRs submitted to FinCEN. Required Action: BSA Officer Marks should revoke the exemption for one Phase II entity and obtain a back filing determination from FinCEN. Once the determination is received, the required CTRs should be submitted. Supporting Comment: One customer that was acquired through merger activity had been granted Phase II status to be exempt from CTR reporting requirements; however, their primary business activity was functioning as an armored car service. According to FinCEN guidance, this type of activity is considered an ineligible business activity and cannot be exempted from CTR reporting requirements. Management’s Response: During the examination, BSA Officer Marks revoked the exemption and contacted FinCEN to obtain a back filing determination. FinCEN determined that CTRs should be back-filed for one year, and management submitted the required CTRs on September 6, 20XX.