BSA/AML Examination Manual - ffiec

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Appendix H: Request Letter Items (Core and Expanded) Appendix H: Request Letter Items (Core and Expanded) Core Examination Procedures As part of the examination planning process, the examiner should prepare a request letter. The list below includes materials that examiners may request or request access to for a bank BSA/AML examination. This list should be tailored for the specific bank’s risk profile and the planned examination scope. Additional materials may be requested as needed. BSA/AML Compliance Program _ Name and title of the designated BSA compliance officer and, if different, the name and title of the person responsible for monitoring BSA/AML compliance. Organization charts showing direct and indirect reporting lines. Copies of resumés and qualifications of person(s) new to the bank serving in BSA/AML compliance program oversight capacities. _ Make available copies of the most recent written BSA/AML compliance program approved by board of directors (or the statutory equivalent of such a program for foreign financial institutions operating in the United States), including Customer Identification Program (CIP) requirements, with date of approval noted in the minutes. _ Make available copies of the policy and procedures relating to all reporting and recordkeeping requirements, including suspicious activity reporting. _ Correspondence addressed between the bank, its personnel or agents, and its federal and state banking agencies, the U.S. Treasury (Office of the Secretary and Department of the Treasury, Internal Revenue Service (IRS), FinCEN, IRS Enterprise Computing Center – Detroit (formerly the Detroit Computing Center), and OFAC) or law enforcement authorities since the previous BSA/AML examination. For example, please make available IRS correspondence related to CTR errors or omissions. Independent Testing _ Make available copies of the results of any internally or externally sourced independent audits or tests performed since the previous examination for BSA/AML, including the scope or engagement letter, management’s responses, and access to the workpapers. FFIEC BSA/AML Examination Manual H–1 8/24/2007
Appendix H: Request Letter Items (Core and Expanded) _ Make available access to the auditor’s risk assessment, audit plan (schedule), and program used for the audits or tests. Training _ Training documentation (e.g., materials used for training since the previous BSA/AML examination). _ BSA/AML training schedule with dates, attendees, and topics. A list of persons in positions for which the bank typically requires BSA/AML training but who did not participate in the training. Risk Assessment _ Make available copies of management’s BSA/AML risk assessment of products, services, customers, and geographic locations. _ List of bank identified high-risk accounts. Customer Identification Program _ List of accounts without taxpayer identification numbers (TINs). _ File of correspondence requesting TINs for bank customers. _ A copy of any account opening forms (e.g., for loans, deposits or other accounts) used to document CIP/Customer Due Diligence information. _ Written description of the bank’s rationale for CIP exemptions for existing customers who open new accounts. _ List of new accounts covering all product lines (including accounts opened by third parties) and segregating existing customer accounts from new customers, for ___________. (Examiner to insert a period of time appropriate for the size and complexity of the bank.) _ List of any accounts opened for a customer that provides an application for a TIN. _ List of any accounts opened in which verification has not been completed or any accounts opened with exceptions to the CIP. _ List of customers or potential customers for whom the bank took adverse action, 244 on the basis of its CIP. _ List of all documentary and nondocumentary methods the bank uses to verify a customer’s identity. 244 As defined by 12 CFR 202.2(c). FFIEC BSA/AML Examination Manual H–2 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
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Enterprise-Wide BSA/AML Compliance
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Corporate management. Enterprise-Wi
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Foreign Branches and Offices of U.S
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Examination Procedures Parallel Ban
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Correspondent Accounts (Domestic)
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Correspondent Accounts (Foreign)
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Correspondent Accounts (Foreign)
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U.S. Dollar Drafts — Overview U.S
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U.S. Dollar Drafts — Examination
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Payable Through Accounts — Overvi
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Payable Through Accounts — Examin
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Payable Through Accounts — Examin
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Risk Mitigation Pouch Activities
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Pouch Activities — Examination Pr
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Electronic Banking — Overview lin
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Examination Procedures Electronic B
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Funds Transfers — Overview and on
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Funds Transfers — Overview busine
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Examination Procedures Funds Transf
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Automated Clearing House Transactio
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Transaction Testing Automated Clear
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Electronic Cash — Overview Using
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Third-Party Payment Processors —
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Third-Party Payment Processors —
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Brokered Deposits — Overview Brok
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Examination Procedures Brokered Dep
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Privately Owned Automated Teller Ma
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• Expected account activity, incl
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Privately Owned ATMs — Examinatio
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Nondeposit Investment Products —
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Nondeposit Investment Products —
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− Holdings in excess of the custo
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Insurance — Overview its insuranc
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Examination Procedures Insurance In
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Concentration Accounts — Overview
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Concentration Accounts — Examinat
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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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Page 287 and 288: Professional Service Providers —
Page 289 and 290: Professional Service Providers —
Page 291 and 292: Non-Governmental Organizations and
Page 293 and 294: Non-Governmental Organizations and
Page 295 and 296: Business Entities (Domestic and For
Page 297 and 298: Risk Factors Business Entities (Dom
Page 303 and 304: Cash-Intensive Businesses — Overv
Page 305 and 306: Appendix A: BSA Laws and Regulation
Page 311 and 312: Appendix B: BSA/AML Directives Appe
Page 313 and 314: Web Sites Appendix C: BSA/AML Refer
Page 315 and 316: Appendix C: BSA/AML References •
Page 317 and 318: Appendix D: Statutory Definition of
Page 319 and 320: Appendix E: International Organizat
Page 321 and 322: Appendix F: Money Laundering and Te
Page 325 and 326: Privately Owned Automated Teller Ma
Page 329 and 330: Funds Transfers Appendix F: Money L
Page 331: Appendix G: Structuring However, tw
Page 335 and 336: Appendix H: Request Letter Items (C
Page 339 and 340: Expanded Examination Procedures App
Page 341 and 342: Parallel Banking _ List any paralle
Page 351 and 352: Appendix I: Risk Assessment Link to
Page 353 and 354: Appendix J: Quantity of Risk Matrix
Page 355 and 356: Appendix K: Customer Risk versus Du
Page 357 and 358: When did the suspicious activity ta
Page 359 and 360: Low No history of OFAC actions. No
Page 361 and 362: Appendix O: Examiner Tools for Tran
Page 363 and 364: Appendix O: Examiner Tools for Tran
Page 365 and 366: Signature Cards Appendix P: BSA Rec
Page 367 and 368: Name and address of the beneficiary
Page 369 and 370: Appendix P: BSA Record Retention Re
Page 371 and 372: Acronym or abbreviation Full name E
Page 373 and 374: Acronym or abbreviation Full name N
Page 375 and 376: Appendix R: Enforcement Guidance Ap
Page 377 and 378: Appendix R: Enforcement Guidance As
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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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