BSA/AML Examination Manual - ffiec

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Appendix H: Request Letter Items (Core and Expanded) correspondence received from FinCEN that acknowledges FinCEN’s receipt of the bank’s notice to voluntarily share information with other financial institutions. _ If applicable, make available copies of policies, procedures, and processes for complying with 31 CFR 103.110. Purchase and Sale of Monetary Instruments _ Access to records of sales of monetary instruments in amounts between $3,000 and $10,000 (if maintained with individual transactions, provide samples of the record made in connection with the sale of each type of monetary instrument). Funds Transfers Recordkeeping _ Access to records of funds transfers, including incoming, intermediary, and outgoing transfers of $3,000 or more. Foreign Correspondent Account Recordkeeping and Due Diligence _ List of all foreign correspondent bank accounts, including a list of foreign financial institutions, for which the bank provides or provided regular services, and the date on which the required information was received (either by completion of a certification or by other means). _ If applicable, documentation to evidence compliance with 31 CFR 103.177 (Prohibition on Correspondent Accounts for Foreign Shell Banks; Records Concerning Owners of Foreign Banks and Agents for Service of Legal Process) and 31 CFR 103.185 (Summons or Subpoena of Foreign Bank Records; Termination of Correspondent Relationship) (for foreign correspondent bank accounts and shell banks). _ List of all payable through relationships with foreign financial institutions as defined in 31 CFR 103.175. _ Access to contracts or agreements with foreign financial institutions that have payable through accounts. _ List of the bank’s foreign branches and the steps the bank has taken to determine whether the accounts with its branches are not used to indirectly provide services to foreign shell banks. _ List of all foreign correspondent bank accounts and relationships with foreign financial institutions that have been closed or terminated in compliance with the conditions in 31 CFR 103.177 (i.e., service to foreign shell banks, records of owners and agents). _ List of foreign correspondent bank accounts that have been the subject of a 31 CFR 103.100 (Information Sharing Between Federal Law Enforcement Agencies and FFIEC BSA/AML Examination Manual H–5 8/24/2007
Appendix H: Request Letter Items (Core and Expanded) Financial Institutions) or any other information request from a federal law enforcement officer for information regarding foreign correspondent bank accounts and evidence of compliance. _ Any notice to close foreign correspondent bank accounts from the Secretary of the Treasury or the U.S. Attorney General and evidence of compliance. _ Make available copies of policies, procedures, and processes for complying with 31 CFR 103.177. _ List of all the bank’s embassy or consulate accounts, or other accounts maintained by a foreign government, foreign embassy, or foreign political figure. _ List of all accountholders and borrowers domiciled outside the United States, including those with U.S. power of attorney. Currency-Shipment Activity _ Make available records reflecting currency shipped to and received from the Federal Reserve Bank or correspondent banks, or reflecting currency shipped between branches and their banks’ central currency vaults for the previous ___________ months. (Examiner to insert a period of time appropriate for the size and complexity of the bank.) Other BSA Reporting and Recordkeeping Requirements _ Record retention schedule and procedural guidelines. _ File of Reports of International Transportation of Currency or Monetary Instruments (CMIR) (FinCEN Form 105, formerly Customs Form 4790). _ Records of Report of Foreign Bank and Financial Accounts (FBAR) (TD F 90-22.1). OFAC _ Name and title of the designated OFAC compliance officer and, if different, the name and title of the person responsible for monitoring OFAC compliance. Organization charts showing direct and indirect reporting lines. Copies of resumés and qualifications of person (or persons) new to the bank serving in OFAC compliance program oversight capacities. _ OFAC training schedule with dates, attendees, and topics. A list of persons in positions for which the bank typically requires OFAC training but who did not participate in the training. _ Make available copies of the results of any internally or externally sourced independent audits or tests performed since the previous examination for OFAC, FFIEC BSA/AML Examination Manual H–6 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 285 and 286: Non-Bank Financial Institutions —
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 and 332: Appendix G: Structuring However, tw
Page 333 and 334: Appendix H: Request Letter Items (C
Page 335: 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
Page 379 and 380: Appendix R: Enforcement Guidance ex
Page 381 and 382: Appendix R: Enforcement Guidance FF
Page 383 and 384: Backfiling. See Currency Transactio
Page 385 and 386: 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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