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

More documents

Recommendations

Info

INFORMATION SHARING – NATIONAL SECURITYLETTERS (NSLS) Written investigative demands that may be issued bythe local Federal Bureau of Investigation (FBI) andother federal government authorities to obtainfinancial records from financial institutions. Highly confidential – examiners will not review. Policies and procedures should be in place to process andmaintain confidentiality of NSLs. SARs should not include their existence. Questions regarding NSLs should be directed tothe local FBI office.PENALTIES FOR BSA VIOLATIONS Credit unions Cease and Desist Order (see “InteragencyGuidance”) Loss of charter (criminal and civil). Criminal money penalties up to the greater of $1million or twice the value of the transaction. Civil money penalties.30
PENALTIES FOR BSA VIOLATIONS Individuals Removal and bar from banking (criminal and civil). Criminal fine of up to $250,000, five years in prison, or bothfor willful violations of the BSA and for structuringtransactions to evade BSA reporting requirements. Criminal find of up to $500,000, ten years in prison, or bothfor violating BSA and any other U.S. law or engaging in apattern of criminal i activity.it Civil money penalties.OFFICE OF FOREIGN ASSETSCONTROL (OFAC) COMPLIANCEExaminer will review the credit union’s OFAC risk assessmentand audit to determine the extent to which an OFAC review isnecessary during the BSA examination.31
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 and 28: CUSTOMER/MEMBERIDENTIFICATION PROGR
Page 29: INFORMATION SHARING314(A) REQUESTS
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

Create successful ePaper yourself

Delete template?

Save as template?