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

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OFAC PROGRAM (RECOMMENDED) Risk assessment Internal controls How transactions will be flagged and reviewed. Defining criteria for comparing names to OFAC list. How it will be determined which hits are valid or false(investigation). Reassessment of OFAC filtering system. Prevention of transactions until comparison is made. Updating the OFAC list.OFAC PROGRAM Process used to block and reject transactions. Managing blocked accounts. Reporting transactions, blocked accounts and prohibitedtransactions. Maintaining licensing information. Independent testing (at least annually) Responsible individual Training34
RESOURCES MCUL: www.mcul.org (InfoSight) NCUA: www.ncua.gov CUNA: www.cuna.org NASCUS: www.nascus.org FinCEN: www.fincen.gov IRS Detroit Computing Center: (800) 800-2877 FinCEN’s Financial Institutions Terrorist Hotline to report terrorist activityagainst the U.S.: 1-866-556-3974 FinCEN’s BSA/AML Examination Manual:www.ffiec.gov/bsa_aml_infobase/pages_manual/manual_online.htmi f b / g l/ l li FBI: www.fbi.gov OFAC: www.treas.gov/ofac35
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 and 30: INFORMATION SHARING314(A) REQUESTS
Page 31 and 32: PENALTIES FOR BSA VIOLATIONS Indivi
Page 33: OFAC - PROHIBITED TRANSACTIONS Proh

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

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