Independent Review for Banks - The Complete BSA/AML Audit WorkbookUsing the FFIEC Examination Manual to conduct an independent review is like using the owner's manual of a car to judge a driver's abilities. Wrong tool for the job! The Complete Audit Workbook ensures that audit professionals and BSA officers have the right tool to conduct the PATRIOT Act (Section 352) required independent review. The Workbook breaks down BSA/AML regulatory requirements into component parts that enable an auditor to judge whether all the i's and t's of a BSA compliance program are dotted and crossed. Guidance for each major category of questions (over 50 in all!) is included. Audit traps, --items seen only in confidential exit interviews-- are also included. The audience for this book is both BSA auditors and compliance officers. The latter can utilize the Workbook to design a comprehensive, sustainable AML program. The former can use this Workbook to check their firm's BSA program status and carry out their duty to keep senior management informed. |
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Contents
INTRODUCTION | 1 |
CDD EDD | 14 |
CORRESPONDENT ACCOUNTS DOMESTIC | 30 |
CURRENCY FLOWS REPORTING LARGE CASH | 57 |
DEPOSIT AND NONDEPOSIT ACCOUNT TYPES | 76 |
EDUCATIONTRAININGAWARENESS | 90 |
ELECTRONIC 3RDPARTY PAYMENT PROCESSOR SERVICES | 107 |
FUNDSWIRE TRANSFER BENEFICIARY BANKS | 122 |
INTERNATIONAL TRANSPORTATION OF CURRENCY | 179 |
KNOW YOUR EMPLOYEE | 204 |
NGOS AND CHARITIES | 218 |
PARALLEL BANKING | 235 |
SENIOR FOREIGN POLITICAL FIGURES | 250 |
PROFESSIONAL SERVICE PROVIDERS | 275 |
REPORT FILING | 299 |
SPECIAL MEASURES | 319 |
INFORMATION SHARING | 135 |
INTERNAL CONTROLS | 155 |
SYSTEMS AND IT SUPPORT | 347 |
TRUST AND ASSET MANAGEMENT SERVICES | 363 |
Common terms and phrases
account activity account opening account relationships adequate anti-money laundering appropriate assets audit automated bank's policies bank’s beneficiary broker/dealer BSA compliance BSA/AML compliance BSA/AML risks business entities cash compliance program concentration accounts conduct correspondent account correspondent banking Currency Transaction Report currency transactions Customer Identification Program customer’s deposit documentation employees enhanced due diligence ensure established Fedwire file a SAR FinCEN Follow-up foreign bank foreign branches foreign financial institution foreign political figure funds transfer high-risk identification number identifying information individual jurisdiction law enforcement maintain monetary instruments money laundering risk NBFI obtain OFAC offshore PATRIOT Act payment order policies and procedures private banking accounts procedures address processes purchase records regulations request requirements risk assessment RISK MITIGATION senior foreign political SFPF specific suspicious activity monitoring Suspicious Activity Report terrorist financing transaction monitoring transmittal order trust U.S. bank U.S. dollar unusual activity USA PATRIOT Act verify Yes No Comments