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

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INTERNAL CONTROLS - REPORTINGCURRENCY TRANSACTION REPORTS Must be filed for each deposit, withdrawal, payment,transfer or other transaction involving currency (cash)of more than $10,000. Multiple transactions by or on behalf of one person inone business day: consolidate the transactions andreport them as one if the total exceeds $10,000. Must be filed within 15 days after the date of thetransaction.INTERNAL CONTROLS - REPORTINGCURRENCY TRANSACTION REPORTS Examples of reportable transactions: Denomination exchanges, IRAs, loan payments, ATMtransactions, purchases of certificates of deposit, depositsand withdrawals, funds transfers paid in currency, andmonetary instrument purchases. Management should ensure that the credit union hasan adequate system to: Aggregate g currency transactions throughout the creditunion; and Appropriately report currency transactions subject to theBSA requirement.14
CURRENCY TRANSACTION REPORTEXEMPTIONS Credit unions may exempt certain types ofmembers from currency transaction reporting. Must file a Designation of Exempt Person formwith the Internal Revenue Service (IRS) Two types of exemptions: Phase I Phase IICURRENCY TRANSACTION REPORTSPHASE I EXEMPTIONS Categories: A federal, state or local government agency or department. Any entity exercising i governmental authority in the U.S. Other financial institutions, to the extent of its domestic operations. Any entity (other than a bank) whose common stock is listed on the NewYork, American, or Nasdaq stock exchanges (with some exceptions). Any subsidiary (other than a bank) of any “listed entity” that is organizedunder U.S. law and at least 51% of whose common stock is owned bythe listed entity. For entities (other than the first three above): Must file a one-time Designation of Exempt Person form with the IRSwithin 30 days after the first transaction in currency that the creditunion wishes to exempt. The credit union must review and verify the information supporting eachdesignation at least once per year.15
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 and 10: RISK ASSESSMENT - PRODUCTS AND SERV
Page 11 and 12: INTERNAL CONTROLS Made up of the cr
Page 13: INTERNAL CONTROLS - REPORTING BSA r
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

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

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