Introductory BSA AML Examiner School Manual Palm Springs 2019

Exam Planning Case Study

You are conducting the BSA/AML examination on the Miller Bank Co. This institution has been in existence since March 1, 2003 and has approximately $527 million in assets. You will be conducting the BSA/ AML examination at the next full scope examination. The last examination was as of June 30, 2013.

The following information has been provided from the last examination report:

ECC Page

Compliance with Bank Secrecy Act (BSA) and Anti Money Laundering (AML) regulations is satisfactory. However, the bank’s written policies and procedures need improvement to provide a description on how management will ensure and monitor compliance with BSA/AML regulations. In particular the areas of high risk accounts and enhanced due diligence need further enhancement. Additionally, the BSA officer needs to establish procedures to provide make up training for employees that cannot attend regularly scheduled BSA training.

The BSA officer agreed to recommendations.

Confidential Page

To ensure that the bank has an adequate BSA/AML compliance program commensurate with its risk profile, examiners conducted the following examination procedures in accordance with the BSA/AML Examination Manual: Scoping & Planning, BSA/AML Risk assessment, BSA/AML Compliance Program, Developing Conclusions and Finalizing the Examination. Additionally, examiners assessed the bank’s policies and procedures to ensure compliance with OFAC sanctions, Information Sharing (transaction testing), and enhanced due diligence for higher risk customers. Transaction testing was performed on OFAC in relationship to loan customers. Testing was performed using the safety and soundness loan review sample. No exceptions were found.

The following information was provided by the bank management:

The Chief Compliance Officer started with the bank on January 15, 2014.

The bank has opened 3 new branches since the last examination.

The bank has an affiliate that issues prepaid access cards, which the bank offers to customers.

Utilizing the FFIEC BSA Manual – what information would you request in the entry letter item?