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BSA/AML Examination Manual - ffiec

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Automated Clearing House Transactions<br />

Appendix H: Request Letter Items (Core and Expanded)<br />

_ Make available copies of any policies and procedures related directly to automated<br />

clearing house (ACH) transactions that are not already included in the <strong>BSA</strong>/<strong>AML</strong><br />

policies.<br />

_ Make available copies of management reports that indicate the monthly volume of<br />

ACH activity.<br />

_ Make available a list of large or frequent ACH transactions.<br />

_ Make available a list of international ACH transactions (both those originated from or<br />

received by the bank).<br />

_ Make available a list of customer complaints regarding ACH transactions.<br />

Electronic Cash<br />

_ Make available copies of any policies and procedures related directly to electronic<br />

cash (e-cash) that are not already included in the <strong>BSA</strong>/<strong>AML</strong> policies.<br />

_ Management reports that indicate the monthly volume of e-cash activity.<br />

_ A list of business customers regularly conducting e-cash transactions, including the<br />

number and dollar volume of transactions.<br />

Third-Party Payment Processors<br />

_ If not already included in the <strong>BSA</strong>/<strong>AML</strong> policies, make available copies of any<br />

policies, procedures, and processes related to third-party payment processors.<br />

_ A list of third-party payment processor relationships. Include the number and dollar<br />

volume of payments processed per relationship.<br />

_ List of SARs filed on third-party payment processor relationships.<br />

Purchase and Sale of Monetary Instruments<br />

_ If not already included in the <strong>BSA</strong>/<strong>AML</strong> policies, make available copies of any<br />

policies, procedures, and processes related to the sale of monetary instruments for<br />

currency. In particular, include policies, procedures, and processes related to the<br />

monitoring sales of monetary instruments in order to detect unusual activities.<br />

_ Monetary instrument logs or other management information systems reports used for<br />

the monitoring and detection of unusual or suspicious activities relating to the sales of<br />

monetary instruments.<br />

_ List of noncustomer transactions over a specified period of time.<br />

FFIEC <strong>BSA</strong>/<strong>AML</strong> <strong>Examination</strong> <strong>Manual</strong> H–11 8/24/2007

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