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

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COMPLIANCE PROGRAM Directors are responsible for ensuring that theircredit unions have a written BSA <strong>compliance</strong>program that is tailored to its level of risk. Written policies, procedures and processes. Must be written, approved by the board ofdirectors and noted in the board minutes.COMPLIANCE PROGRAM Made up of the following: Risk Assessment Internal Controls Independent Testing Designation of BSA/AML Compliance Officer Training Customer (Member) Identification Program (CIP)6
RISK ASSESSMENTThe risk assessment will determine the policies, proceduresand processes for BSA/AML <strong>compliance</strong>RISK ASSESSMENT7
Page 3 and 4: BSA/AML BACKGROUND AND PURPOSE Made
Page 5: PRE-EXAM REVIEW Contact management
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 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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