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

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CURRENCY TRANSACTION REPORTSEXEMPTION SAFE HARBOR Safe harbor from civil penalties for the failure to file aCTR for transactions in currency by an exempt person,unless the credit union knowingly provides false orincomplete information, or has reason to believe thatthe member does not qualify as an exempt member. Safe harbor does NOT apply to the filing of suspiciousactivity reports (SARs). The credit union must still retainrecords of funds transferred, or records in connection withthe sale of monetary instruments to that person.SUSPICIOUS ACTIVITY REPORTS(SARS)Examiner will assess policies, procedures, processes andoverall compliance with statutory and regulatory requirementsfor monitoring, detecting And reporting suspicious activities18
INTERNAL CONTROLS - REPORTINGSUSPICIOUS ACTIVITY REPORTS Credit unions are required to file a SAR withrespect to the following: Criminal violations involving insider abuse in anyamount. Criminal violations aggregating $5,000 or morewhen a suspect can be identified. Criminal violations aggregating $25,000 or moreregardless of a potential suspect.INTERNAL CONTROLS - REPORTINGSUSPICIOUS ACTIVITY REPORTS Transactions conducted or attempted by, at or through acredit union aggregating $5,000 or more, of the credit unionknows, suspects or has reason to suspect that thetransaction: May involve potential money laundering or other illegalactivity. Is designed to evade the BSA or its implementingregulations. Has no business or apparent lawful purpose, or is not thetype of transaction that the particular member wouldnormally be expected to engage in, and the credit unionknows of no reasonable explanation for the transaction.19
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 and 14: INTERNAL CONTROLS - REPORTING BSA r
Page 15 and 16: CURRENCY TRANSACTION REPORTEXEMPTIO
Page 17: CURRENCY TRANSACTION REPORTSPHASE I
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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