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

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RISK ASSESSMENT The risk assessment, though the use of a Risk Matrix,should identify and measure the degree of risk foreach of the following: Products & services; Members; and Geographic locations. Identify steps that have been taken to mitigate risk. Should evolve as new products and services areintroduced or changed, expansions occur throughmergers, and/or field of membership enlarges. Recommended every 12 to 18 months.RISK ASSESSMENT – RISK MATRIX[Product/Service;Members;GeographicLocation]Degree ofRisk (low,medium,high)Areas ofConcernRisk Controls8
RISK ASSESSMENT – PRODUCTS AND SERVICES What types of products and services does thecredit union offer? Who is using them? Where is the potential exposure to <strong>money</strong><strong>laundering</strong>? What steps have been taken to mitigate risk?RISK ASSESSMENT - MEMBERS Who does your credit union serve? What services do they use? What is their source of funds? Where are they located?9
Page 3 and 4: BSA/AML BACKGROUND AND PURPOSE Made
Page 5 and 6: PRE-EXAM REVIEW Contact management
Page 7: RISK ASSESSMENTThe risk assessment
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

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