BSA/AML Examination Manual - ffiec

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Appendix H: Request Letter Items (Core and Expanded) _ Make available a list of foreign correspondent bank accounts with PTAs. Include a detailed summary (number and monthly dollar volume) of sub-accountholders for each PTA. _ List of SARs filed relating to PTAs. Pouch Activities _ Make available copies of pouch activity policies, procedures, and processes, including procedures for monitoring for suspicious activity. _ List of customer accounts permitted to use pouch services. _ List of CTRs, CMIRs, or SARs filed relating to pouch activity. _ As needed, a copy of pouch logs. Foreign Branches and Offices of U.S. Banks _ Make available copies of policies, procedures, and processes specific to the foreign branch or office, if different from the parent’s policies, procedures, and processes. _ Most recent management reports received on foreign branches and offices. _ Make available copies of the bank’s tiering or organizational structure report. _ AML audit reports, compliance reports, and supporting documentation for the foreign branches and offices. _ List of the types of products and services offered at the foreign branches and offices and information on new products or services offered by the foreign branch, including those that are not already offered by the parent bank. _ A description of the method for aggregating each customer relationship across business units and geographic locations throughout the organization. _ Code of ethics for foreign branches or offices, if it is different from the bank’s standard policy. _ When testing will be performed, a list of accounts originated or serviced in the foreign branch or office. Examiners should try to limit this request and focus on accounts for specific products or services, high-risk accounts only, or accounts for which exceptions or audit concerns have been noted. _ List of the locations of foreign branches and offices, including, if possible, the host country regulatory agency and contact information. _ Organizational structure of the foreign branches and offices, including reporting lines to the U.S. bank level. FFIEC BSA/AML Examination Manual H–9 8/24/2007
Parallel Banking _ List any parallel banking relationships. Appendix H: Request Letter Items (Core and Expanded) _ Make available copies of policies, procedures, and processes specifically for parallel banking relationships, including procedures relating to high-risk money laundering activities. Such policies and procedures should include those that are specific to the relationship with the parallel entity. _ List of SARs filed relating to parallel banking relationships. _ Documents that specify limits or procedures that should be followed when dealing with the parallel entity. _ A list of directors or officers of the bank who are also associated with the foreign parallel bank. Electronic Banking _ Make available copies of any policies and procedures related directly to electronic banking (e-banking) that are not already included in the BSA/AML policies. _ Management reports that indicate the monthly volume of e-banking activity. _ A list of business customers regularly conducting e-banking transactions, including the number and dollar volume of transactions. Funds Transfers _ Funds transfer activity logs, including transfers into and out of the bank. Include the number and dollar volume of funds transfer activity for the month. _ List of funds transfers purchased with currency over a specified time period. _ List of noncustomer transactions over a specified time period. _ If not already included in the BSA/AML policies, make available copies of any policies, procedures, and processes related to funds transfers or payable upon proper identification (PUPID). _ List of suspense accounts used for PUPID proceeds. _ List of PUPID transactions completed by the bank, either as the beneficiary bank or as the originating bank. FFIEC BSA/AML Examination Manual H–10 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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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 339: Expanded Examination Procedures App
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
Page 387 and 388: money services businesses, 279 nond
Page 389 and 390: 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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