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Electronic Banking — Overview • Obtaining expected account activity from the RDC customer, such as the anticipated RDC number volume, dollar volume, and type (e.g., payroll checks, third-party checks, traveler’s checks). • In contracts, requiring RDC customers to retain, protect, and ultimately destroy original documents. This may also include requirements that the RDC customer provide original documents to the bank when needed to facilitate investigations related to unusual transactions or poor quality transmissions, or to resolve disputes. Additional monitoring or review when significant changes occur in the type or volume of transactions, or when significant changes occur in the underwriting criteria that the bank relied on when establishing RDC services. • Ensuring that RDC customers properly secure equipment and prevent inappropriate use, including establishing effective equipment security controls (e.g., passwords, dual control access). • Using improved aggregation and monitoring capabilities as facilitated by the digitized data. FFIEC BSA/AML Examination Manual 190 8/24/2007
Examination Procedures Electronic Banking Electronic Banking — Examination Procedures Objective. Assess the adequacy of the bank’s systems to manage the risks associated with electronic banking (e-banking) customers, including Remote Deposit Capture (RDC) activity, and management’s ability to implement effective monitoring and reporting systems. 1. Review the policies, procedures, and processes related to e-banking, including RDC activity as appropriate. Evaluate the adequacy of the policies, procedures, and processes given the bank’s e-banking activities and the risks they present. Assess whether the controls are adequate to reasonably protect the bank from money laundering and terrorist financing. 2. From a review of management information systems (MIS) and internal risk rating factors, determine whether the bank effectively identifies and monitors high-risk ebanking activities. 3. Determine whether the bank’s system for monitoring e-banking, including RDC activity as appropriate, for suspicious activities, and for reporting suspicious activities, is adequate given the bank’s size, complexity, location, and types of customer relationships. 4. If appropriate, refer to the core examination procedures, “Office of Foreign Assets Control,” page 146, for guidance. Transaction Testing 5. On the basis of the bank’s risk assessment of its e-banking activities, as well as prior examination and audit reports, select a sample of e-banking accounts. From the sample selected, perform the following procedures: Review account opening documentation, including Customer Identification Program (CIP) and transaction history. Compare expected activity with actual activity. Determine whether the activity is consistent with the nature of the customer’s business. Identify any unusual or suspicious activity. 6. On the basis of examination procedures completed, including transaction testing, form a conclusion about the adequacy of policies, procedures, and processes associated with e-banking relationships. FFIEC BSA/AML Examination Manual 191 8/24/2007
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Bank Secrecy Act / Anti-Money Laund
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Table of Contents EXPANDED EXAMINAT
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INTRODUCTION Introduction This Fede
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Background Introduction In 1970, Co
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Introduction institutions, such as
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Introduction proliferation of weapo
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Introduction Although the motivatio
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Scoping and Planning — Overview C
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Scoping and Planning — Overview T
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Scoping and Planning — Examinatio
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Scoping and Planning — Examinatio
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BSA/AML Risk Assessment — Overvie
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Analysis of Specific Risk Categorie
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BSA/AML Risk Assessment — Examina
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BSA/AML Compliance Program — Over
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BSA/AML Compliance Program — Exam
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Developing Conclusions and Finalizi
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Developing Conclusions and Finalizi
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Customer Identification Program —
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Customer Information Required Custo
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Transaction Testing Customer Identi
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Customer Due Diligence — Overview
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Customer Due Diligence — Examinat
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Suspicious Activity Reporting — O
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Law Enforcement Inquiries and Reque
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Timing of a SAR Filing Suspicious A
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Suspicious Activity Reporting — E
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Suspicious Activity Reporting — E
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Currency Transaction Reporting —
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Currency Transaction Reporting —
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Currency Transaction Reporting Exem
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• Operating a pawn brokerage. Cur
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Currency Transaction Reporting Exem
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Information Sharing — Overview In
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Information Sharing — Overview su
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Information Sharing — Overview es
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Copies of section 314(a) requests.
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Purchase and Sale of Monetary Instr
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Funds Transfers Recordkeeping — O
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Funds Transfers Recordkeeping — O
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Responsibilities of Beneficiary’s
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Funds Transfers Recordkeeping — E
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Foreign Correspondent Account Recor
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Private Banking Due Diligence Progr
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Special Measures — Overview minim
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Examination Procedures Special Meas
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Foreign Bank and Financial Accounts
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International Transportation of Cur
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Office of Foreign Assets Control
Page 143 and 144: Office of Foreign Assets Control
Page 153 and 154: Enterprise-Wide BSA/AML Compliance
Page 159 and 160: Corporate management. Enterprise-Wi
Page 161 and 162: Foreign Branches and Offices of U.S
Page 167 and 168: Examination Procedures Parallel Ban
Page 169 and 170: Correspondent Accounts (Domestic)
Page 175 and 176: Correspondent Accounts (Foreign)
Page 177 and 178: Correspondent Accounts (Foreign)
Page 179 and 180: U.S. Dollar Drafts — Overview U.S
Page 181 and 182: U.S. Dollar Drafts — Examination
Page 183 and 184: Payable Through Accounts — Overvi
Page 185 and 186: Payable Through Accounts — Examin
Page 187 and 188: Payable Through Accounts — Examin
Page 189 and 190: Risk Mitigation Pouch Activities
Page 191 and 192: Pouch Activities — Examination Pr
Page 193: Electronic Banking — Overview lin
Page 197 and 198: Funds Transfers — Overview and on
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Page 201 and 202: Examination Procedures Funds Transf
Page 203 and 204: Automated Clearing House Transactio
Page 209 and 210: Transaction Testing Automated Clear
Page 211 and 212: Electronic Cash — Overview Using
Page 213 and 214: Third-Party Payment Processors —
Page 215 and 216: Third-Party Payment Processors —
Page 217 and 218: Purchase and Sale of Monetary Instr
Page 219 and 220: Brokered Deposits — Overview Brok
Page 221 and 222: Examination Procedures Brokered Dep
Page 223 and 224: Privately Owned Automated Teller Ma
Page 225 and 226: • Expected account activity, incl
Page 227 and 228: Privately Owned ATMs — Examinatio
Page 229 and 230: Nondeposit Investment Products —
Page 231 and 232: Nondeposit Investment Products —
Page 233 and 234: − Holdings in excess of the custo
Page 235 and 236: Insurance — Overview its insuranc
Page 237 and 238: Examination Procedures Insurance In
Page 239 and 240: Concentration Accounts — Overview
Page 241 and 242: Concentration Accounts — Examinat
Page 243 and 244: Lending Activities — Overview bus
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Trade Finance Activities — Overvi
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Risk Mitigation Trade Finance Activ
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Trade Finance Activities — Overvi
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Private Banking — Overview Privat
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Customer Risk Assessment Private Ba
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Private Banking — Overview determ
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Offshore entities. Cash-intensive b
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Trust and Asset Management Services
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• The type of trust or agency acc
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Transaction Testing Trust and Asset
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Nonresident Aliens and Foreign Indi
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Nonresident Aliens and Foreign Indi
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Politically Exposed Persons — Ove
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Politically Exposed Persons — Ove
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Politically Exposed Persons — Exa
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Embassy and Foreign Consulate Accou
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Embassy and Foreign Consulate Accou
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Non-Bank Financial Institutions —
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Professional Service Providers —
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Professional Service Providers —
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Non-Governmental Organizations and
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Non-Governmental Organizations and
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Business Entities (Domestic and For
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Risk Factors Business Entities (Dom
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Cash-Intensive Businesses — Overv
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Appendix A: BSA Laws and Regulation
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Appendix B: BSA/AML Directives Appe
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Web Sites Appendix C: BSA/AML Refer
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Appendix C: BSA/AML References •
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Appendix D: Statutory Definition of
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Appendix E: International Organizat
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Appendix F: Money Laundering and Te
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Privately Owned Automated Teller Ma
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Funds Transfers Appendix F: Money L
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Appendix G: Structuring However, tw
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Appendix H: Request Letter Items (C
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Expanded Examination Procedures App
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Parallel Banking _ List any paralle
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Appendix I: Risk Assessment Link to
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Appendix J: Quantity of Risk Matrix
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Appendix K: Customer Risk versus Du
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When did the suspicious activity ta
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Low No history of OFAC actions. No
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Appendix O: Examiner Tools for Tran
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Appendix O: Examiner Tools for Tran
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Signature Cards Appendix P: BSA Rec
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Name and address of the beneficiary
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Appendix P: BSA Record Retention Re
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Acronym or abbreviation Full name E
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Acronym or abbreviation Full name N
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Appendix R: Enforcement Guidance Ap
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Appendix R: Enforcement Guidance As
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Appendix R: Enforcement Guidance ex
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Appendix R: Enforcement Guidance FF
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Backfiling. See Currency Transactio
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overview, 165-167 request letter it
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money services businesses, 279 nond
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Export Administration Act of 1979,
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Index 314(a) record searches, 88 Cu
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Index for a BSA/AML compliance prog
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guidance on providing banking servi
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247, 253, H-15 Offshore Financial C
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trade finance activities, H-14 trus
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enterprise-wide, 149-150, 152, 153
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U United Nations, 7, 137 Updating O
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