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Annual
BSA/AML compliance reviews performed by
CSI for the Bank or Credit Union would satisfy the
federal requirement that financial
institutions perform an annual BSA/AML
“independent test” to ensure
compliance with the Act’s reporting
and record keeping requirements.
CSI’s BSA/AML compliance review
focuses on a institution's compliance with
the Act’s:
(1) currency transaction
reporting requirements, (2) anti-money
laundering guidelines, (3) record
keeping and retention requirements, (4)
USA PATRIOT Act requirements, (5) OFAC
requirements; and
(6) requirements for maintaining
adequate and effective BSA/AML policies,
procedures, and employee training. Specific
components of the BSA/AML compliance
review would include, as applicable: · Discussions
with key personnel involved in the BSA/AML
compliance process. ·
Reviewing
the institution's
BSA/AML policies and
procedures. · Reviewing
currency transaction documentation to
verify the accuracy of the aggregation
reports. · Reviewing
the institution's
aggregation reports to
determine that CTRs were completed when
required. · Reviewing
CTRs for accuracy, completeness, and
filing timeliness. · Reviewing
the institution's
aggregation reports to test
for suspicious activity. · Reviewing
the institution's
monitoring system used to
detect structuring activities. · Reviewing
suspicious activity reporting procedures
and Suspicious Activity Reports. · Reviewing
record retention procedures for the cash
sales of monetary instruments in amounts
of $3,000 and greater. · Reviewing
record retention procedures for all
other BSA/AML related documentation. · Reviewing
the institution's
exemption procedures and
testing the validity and reasonableness
of the exemptions. · Reviewing
the institution's
Customer Identification
Program (“CIP”) for compliance with
Section 326 of the USA PATRIOT Act. · Reviewing
a sampling of deposit accounts and loans
for compliance with the institution's
CIP. · Reviewing
compliance with other USA PATRIOT Act
requirements. · Reviewing
procedures for accounts with missing tax
ID or social security numbers. · Reviewing
a sampling of outgoing and incoming
wires for compliance with the funds
transfer recordkeeping rules.
· Reviewing
Office of Foreign Assets Control (“OFAC”)
procedures. · Reviewing BSA/AML training records.
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