BSA/AML Examination Manual - ffiec

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Appendix H: Request Letter Items (Core and Expanded) _ Management reports covering 25 to 50 of the largest, most active, and most profitable NDIP customers. _ SARs and subpoenas related to NDIP customers. _ Copy of account opening documentation or agreements for NDIP. _ Copy of contracts or agreements between the bank and third-party NDIP providers for the completion of CIP, due diligence, and ongoing monitoring of NDIP customers. Insurance _ Make available copies of BSA/AML policies and procedures related to the sale of insurance. _ Risk assessment covering insurance products. _ Management information systems reports related to the sales of insurance products. Reports may include large transaction reports, single premium payments, early cancellation, premium overpayments, and assignments of claims. _ Copy of contracts or agreements between the bank and insurance providers for the completion of CIP, due diligence, and ongoing monitoring of insurance customers. _ List of insurance products approved for sale at the bank. _ Management reports covering insurance products (including large transactions, funds transfers, single premium payments, and early cancellations). _ SARs or subpoenas related to insurance clients. _ Copy of account documentation requirements and applications for insurance products. Concentration Accounts _ Make available copies of BSA/AML policies, procedures, and processes that are specific to concentration accounts (also known as special-use, omnibus, suspense, settlement, intraday, sweep, or collection accounts). _ List of all concentration accounts and each account’s most recent reconcilement. _ Account activity reports for concentration accounts for ___________. (Examiner to insert a period of time appropriate for the size and complexity of the bank.) Lending Activities _ Make available copies of BSA/AML policies and procedures specific to lending. _ Risk assessment relating to the lending function, including a list of any high-risk lending relationships identified by the bank. FFIEC BSA/AML Examination Manual H–13 8/24/2007
Appendix H: Request Letter Items (Core and Expanded) _ For loans secured by cash collateral, marketable securities, or cash surrender value of life insurance products: A list of all loans that have defaulted since the previous BSA/AML examination, including those that were charged off. A list of all loans that have been extended since the previous BSA/AML examination. Trade Finance Activities _ Make available copies of BSA/AML policies and procedures specific to trade finance activities. _ Risk assessment relating to trade finance activities, including a list of any high-risk trade finance transactions, accounts, or relationships identified by the bank. _ List of customers involved in transactions with high-risk geographic locations or for whom the bank facilitates trade finance activities with high-risk geographic locations. Private Banking _ Make available copies of policies, procedures, and controls used to manage BSA/AML risks in the private banking department. _ Business or strategic plans for the private banking department. _ The most recent version of management reports on private banking activity, such as customer aggregation reports, policy exception reports, client concentrations, customer risk classification reports, and unusual account activity. _ Recent private banking reports from compliance, internal audit, risk management, and external auditors or consultants that cover BSA/AML. _ List of products and services offered to private banking clients. Information on new products and services offered to private banking clients and the bank’s process for approving new activities. _ A description of the method for aggregating customer holdings and activities across business units throughout the organization. _ A description of account officer and manager positions, and the compensation, recruitment, and training program for these positions. _ Code of ethics policy for private banking officers. _ Risk assessment covering private banking customers and transactions. _ List of suspense, concentration, or omnibus accounts used for private banking transactions. Describe the purpose for each account and the controls governing it. FFIEC BSA/AML Examination Manual H–14 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 —
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Professional Service Providers —
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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 and 340: Expanded Examination Procedures App
Page 341 and 342: Parallel Banking _ List any paralle
Page 343: Appendix H: Request Letter Items (C
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,
Page 391 and 392: Index 314(a) record searches, 88 Cu
Page 393 and 394: 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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