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

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INFORMATION SHARINGExaminer will assess compliance with the statutory andregulatory requirements for information sharingINFORMATION SHARING Sections 314(a) and (b) of the USA PATRIOT Act. Two types of information sharing: Between the law enforcement and financialinstitutions [314(a)]; and Between financial institutions [314(b)].28
INFORMATION SHARING314(A) REQUESTS Between the Credit Union and Law Enforcement FinCEN may require a credit union to search its records todetermine whether it maintains or has maintained accountsfor, or engaged in transactions with a specified person,entity or organization during the past 12 months (or 6months if there is a transaction where no account isinvolved). Must report to FinCEN within 14 days, unless the requestspecifies otherwise. Must be kept confidential.INFORMATION SHARING314(B) REQUESTS Between Financial Institutions A financial institution must notify FinCEN of its intent to engagegin information sharing, and that it has established and willmaintain adequate procedures to protect the information. A notice to share information is effective for one year. Should ensure that the other financial institution or associationhas filed its required FinCEN notice. Cannot share SARs or SAR filing information. If request relates to a transaction subject to a SAR, discloseonly the transaction and member information requested.29
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 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: CUSTOMER/MEMBERIDENTIFICATION PROGR
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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