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

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Internal Controls - Reporting• BSA requires financial institutions to file thefollowing reports with the Financial CrimesEnforcement Network (FinCEN):– Currency Transaction Reports (CTRs)• CTR Exemption Forms (if applicable)– Suspicious Activity Reports (SARs)
CURRENCY TRANSACTIONREPORTSExaminer will assess compliance with thestatutory and regulatory requirements for largecurrency transaction reporting
Page 1 and 2: BANK SECRECY ACT / ANTI-MONEY LAUND
Page 3 and 4: BSA/AML Acronyms• BSA/AML - Bank
Page 5 and 6: BSA/AML Purpose• Purpose:- To hel
Page 7 and 8: Pre-Exam Review• Review of BSA da
Page 9 and 10: COMPLIANCE PROGRAMEvery credit unio
Page 11 and 12: Compliance Program• Made up of th
Page 13 and 14: Risk Assessment
Page 15 and 16: Risk Assessment - Risk Matrix• Pr
Page 17 and 18: Risk Assessment - Members• Who do
Page 19 and 20: INTERNAL CONTROLSWritten policies,
Page 21 and 22: Internal Controls• Board ultimate
Page 23: Internal Controls - MonitoringMembe
Page 27 and 28: Internal Controls - ReportingCurren
Page 29 and 30: CTR - Entities Ineligible for Exemp
Page 31 and 32: Currency Transaction ReportsExempti
Page 33 and 34: Internal Controls - Reporting SAR
Page 35 and 36: Internal Controls - Reporting SARs
Page 37 and 38: Internal Controls - Reporting SARs
Page 39 and 40: Internal Controls - Recordkeeping
Page 41 and 42: Independent Testing• Should be co
Page 43 and 44: BSA Compliance Officer(s)• Must b
Page 45 and 46: Training• All staff whose duties
Page 47 and 48: CUSTOMER/MEMBERIDENTIFICATION PROGR
Page 49 and 50: INFORMATION SHARINGExaminer will as
Page 51 and 52: Information Sharing - 314(a) Reques
Page 53 and 54: Information Sharing - National Secu
Page 55 and 56: Penalties for BSA Violations• Ind
Page 57 and 58: OFAC• Requirements are separate a
Page 59 and 60: OFAC - Prohibited Transactions• P
Page 61 and 62: OFAC Program (Recommended)• Risk
Page 63: Resources• MCUL: www.mcul.org (In

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

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