Large Bank Supervision Forum eBook

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Top 20 BSA Warning Signs . . . 1. Not updating OFAC policies and procedures to address changing sanctions programs. 2. Backlogs in BSA related processes, such as processing alerts, cases, and EDD high-risk reviews. 3. Sta ffi ng turnover leading to inadequate or inexperienced BSA/AML/OFAC sta ffi ng. 4. Lack of adequate controls, either an independent audit func Ɵ on or internal quality assurance processes. 5. Risk Assessment not updated with current products/services or markets. 6. Risk Assessment and controls not reflecting third-party and fourth-party rela Ɵ onships. 7. High volume of alerts with low number of actual hits—not properly “dialed in” AML monitoring. 8. High volume of alerts per BSA/AML employee. 9. Alerts closed with inadequate or no documenta Ɵ on. 10. No SAR decision records with cut and paste templates; little to no case-speci fi c analysis.

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Top 20 BSA Warning Signs (continued). . .

11. Inadequate analysis for No SAR decisions. Using "known customer" to justify these decisions is insufficient. 12. Reliance on bank’s business personnel to complete CDD paperwork or to “answer” for any missing informa Ɵ on. 13. Conduct business with charities 14. Conduct business with Private Banking Accounts 15. Have correspondent accounts for foreign financial institutions

16. Conduct business with Foreign Shell Banks 17. Conduct business with Foreign Political Figures

18. Operate in high risk jurisdictions 19. Have offshore funding sources 20. Have offshore transfer of funds

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