bank secrecy act / anti-money laundering (bsa/aml) compliance

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RISK ASSESSMENT – GEOGRAPHIC LOCATION High-risk locations can be foreign or domestic. Domestic high-risk geographic locations include: High Intensity Drug Trafficking Areas (HIDTAs) http://www.whitehousedrugpolicy.gov/hidta/ High Intensity Financial Crime Areas (HIFCAs) www.irs.gov/compliance/enforcement/article/0,,id=107488,00.html#hifca http://www.fincen.gov/le_hifcadesign.html Michigan HIDTA counties: Wayne, Macomb, Oakland, Washtenaw, Genessee, Kent,Kalamazoo, Allegan, Saginaw and Van BurenINTERNAL CONTROLSWritten policies, procedures and practices must be designed tolimit and control risks, and to achieve compliance with the BSA10
INTERNAL CONTROLS Made up of the credit union’s: Monitoringi Reporting Currency Transaction Reports (CTRs) CTR Exemptions Suspicious Activity Reports (SARs) RecordkeepingINTERNAL CONTROLS Board of directors ultimately responsible for ensuringthe credit union has an effective internal controlstructure. Policies, procedures and processes should be in placeto monitor and identify unusual activity. The level of monitoring is dictated by the credit union’srisk assessment, with an emphasis on high-riskproducts, services, members and geographiclocations.11
Page 3 and 4: BSA/AML BACKGROUND AND PURPOSE Made
Page 5 and 6: PRE-EXAM REVIEW Contact management
Page 7 and 8: RISK ASSESSMENTThe risk assessment
Page 9: RISK ASSESSMENT - PRODUCTS AND SERV
Page 13 and 14: INTERNAL CONTROLS - REPORTING BSA r
Page 15 and 16: CURRENCY TRANSACTION REPORTEXEMPTIO
Page 17 and 18: CURRENCY TRANSACTION REPORTSPHASE I
Page 19 and 20: INTERNAL CONTROLS - REPORTINGSUSPIC
Page 21 and 22: INTERNAL CONTROLS - REPORTINGSUSPIC
Page 23 and 24: INTERNAL CONTROLS - RECORDKEEPING F
Page 25 and 26: BSA COMPLIANCE OFFICER(S) Must be a
Page 27 and 28: CUSTOMER/MEMBERIDENTIFICATION PROGR
Page 29 and 30: INFORMATION SHARING314(A) REQUESTS
Page 31 and 32: PENALTIES FOR BSA VIOLATIONS Indivi
Page 33 and 34: OFAC - PROHIBITED TRANSACTIONS Proh
Page 35: RESOURCES MCUL: www.mcul.org (InfoS

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