BSA/AML Examination Manual - ffiec

Developing Conclusions and Finalizing the Examination — Examination Procedures
The BSA/AML compliance program must also include a written Customer
Identification Program (CIP) appropriate for the bank’s size, location, and type of
business.
The examiner should ensure that workpapers are prepared in sufficient detail to
support issues discussed in the report of examination (ROE). The examiner does not
need to provide a written comment on every one of the following items 8 through
15. Written comments should cover only areas or subjects pertinent to the examiner’s
findings and conclusions. All significant findings must be included in the ROE. To
the extent that the following items are discussed in the workpapers, but not the ROE,
the examiner should ensure that the workpapers thoroughly and adequately document
each review, as well as any other aspect of the bank’s BSA/AML compliance
program that merits attention, but may not rise to the level of being included in the
ROE. As applicable, the examiner should prepare a discussion of the following
items.
8. Describe whether the bank’s polices and procedures for law enforcement requests for
information under section 314(a) of the Patriot Act (31 CFR 103.100) meet regulatory
requirements.
9. If the bank maintains any foreign correspondent or private banking accounts for non-
U.S. persons, describe whether the bank’s due diligence policies, procedures, and
processes meet regulatory requirements under section 312 of the Patriot Act (31 CFR
103.176 and 103.178).
10. Describe the board of directors’ and senior managements’ commitment to BSA/AML
compliance. Consider whether management has the following:
A strong BSA/AML compliance program fully supported by the board of
directors.
A requirement that the board of directors and senior management are kept
informed of BSA/AML compliance efforts, audit reports, any compliance failures,
and the status of corrective actions.
11. Describe whether the bank’s policies, procedures, and processes for SAR filings meet
the regulatory requirements and are effective.
12. Describe whether the bank’s policies, procedures, and processes for large currency
transactions meet the requirements of 31 CFR 103.22 and are effective.
13. If applicable, describe whether the bank’s policies, procedures, and processes for
Currency Transaction Report (CTR) exemptions meet regulatory reporting
requirements, appropriately grant exemptions, and use the correct forms.
14. Describe whether the bank’s funds transfer policies, procedures, and processes meet
the requirements of 31 CFR 103.33(e) and (g). Briefly discuss whether the policies,
procedures, and processes include effective internal controls (e.g., separation of
FFIEC BSA/AML Examination Manual 43 8/24/2007