BSA/AML Programs
Annual BSA/AML compliance reviews performed by CSI for financial institutions 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:
- Reviewing BSA/AML training records.
- Reviewing the institution’s Remote Deposit Capture program, including the Remote Deposit Capture contract.
- Reviewing the institution’s procedures for international ACH transactions.
- Reviewing the institution’s procedures for sale of stored value cards and monitoring of sales activity.
- Reviewing a sampling of cash orders and shipments to test for suspicious activity.
- Reviewing the institution’s monitoring system used to detect structuring activities.
- Reviewing the institution’s Money Services Business (“MSB”) customers for compliance with the USA PATRIOT Act and anti-money laundering laws.
- Reviewing the institution’s BSA/AML and OFAC Risk Assessment and analysis.
- Reviewing corrective action taken as a result of the last BSA/AML Examination.
- 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.