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. |
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
addition adequate agencies amounts applicable appropriate assessment assets associated audit authority bank's bank’s banking accounts beneficiary BSA/AML cash checks companies compliance conduct considered controls correspondent account currency customer’s deposit designated determine documentation due diligence effective employees ensure entities established examination example exempt exist expected factors federal financial institution FinCEN Follow-up foreign bank foreign financial institution funds transfer identify identity individual internal involved issued jurisdiction locations maintain monetary instruments money laundering monitoring obtain OFAC offered opening operations payment period person policies and procedures private banking processes purchase reasonable received records references regarding regulations relationships reports request requirements responsibilities risk rule securities specific suspicious activity transactions trust United unusual verify Yes No Comments