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

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OFAC - Reporting• Blocked transactions – within 10 days of theoccurrence, and annually by September 30 (for thoseblocked as of June 30)• Prohibited transactions – within 10 days of theoccurrence• Must keep full and accurate record of each blockedand rejected transaction for 5 years after the date ofthe transaction• For blocked property, records must be retained for 5years after the property is unblocked
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– Process used to block and reject transactions– Managing blocked accounts
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BANK SECRECY ACT / ANTI-MONEY LAUND
Page 3 and 4:
BSA/AML Acronyms• BSA/AML - Bank
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BSA/AML Purpose• Purpose:- To hel
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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 and 24: Internal Controls - MonitoringMembe
Page 25 and 26: CURRENCY TRANSACTIONREPORTSExaminer
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: OFAC - Prohibited Transactions• P
Page 63: Resources• MCUL: www.mcul.org (In
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bank secrecy act / anti- money laundering (bsa/aml) compliance

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