Introductory BSA/AML Examiner School, Providence, RI

• Training of personnel from all applicable areas of the bank.[3] • Frequency of training. • Documentation of attendance records and training materials. • Coverage of bank policies, procedures, processes, and new rules and regulations. • Coverage of different forms of money laundering and terrorist financing as it relates to identification and examples of suspicious activity. • Penalties for noncompliance with internal policies and regulatory requirements. • Accounts or customers identified in the review of information obtained from downloads from the BSA-reporting database. • Higher-risk products and services, customer and entities, and geographic locations for which it appears from the scoping and planning process that the bank may not have appropriate internal • New products and services, customers and entities, and geographies introduced into the bank’s portfolio since the previous BSA/AML examination. Independent Testing 14. Select a judgmental sample that includes transactions other than those tested by the independent auditor and determine whether independent testing: • Is comprehensive, adequate, and timely. • Has reviewed the accuracy of MIS used in the BSA/AML compliance program. • Has reviewed suspicious activity monitoring systems to include the identification of unusual activity. • Has reviewed whether suspicious activity reporting systems include the research and referral of unusual activity Comment: Preliminary Evaluation Transaction testing must include, at a minimum, either examination procedures detailed below (independent testing) or transaction testing procedures selected from within the core or expanded sections. While some transaction testing is required, examiners have the discretion to decide what testing to conduct. Examiners should document their decision regarding the extent of transaction testing to conduct and the activities where it is to be performed, as well as the rationale for any changes to the scope of transaction testing that occur during the examination. Examiners should consider the following After the examiner has completed the review of all four required elements of the bank’s BSA/AML compliance program, the examiner should document a preliminary evaluation of the bank’s program. At this point, the examiner should revisit the initial examination plan, in order to determine whether any strengths or weaknesses identified during the review of the institution’s BSA/AML compliance program warrant adjustments to the initial planned scope. The examiner may complete the core examination procedures, “Office of Foreign Assets Control” (page 157 in the manual). The examiner should document and support any changes to the examination scope, then proceed to the applicable core and, if warranted, expanded examination procedures. If there are no changes to the examination scope, the examiner should proceed to the core examination procedures, “Developing Conclusions and Finalizing the Examination” (page 48 in the manual). Comment: Transaction Testing

Workprogram for Examination Procedures