Item No: BSASCH-M
Recent Congressional focus and well-publicized BSA enforcement actions and fines continue to support a climate proving BSA compliance remains of paramount importance to all financial institutions. Treasury continues to rely on financial institutions to serve as the “front-line gatekeepers” for law enforcement efforts to safeguard the U.S. financial system from the abuses of financial crimes, including money laundering and terrorist financing. The federal regulatory agencies continue to rely on financial institutions to take “every reasonable step” to identify, minimize, and manage any risks that illicit financial activity may pose to the individual institution and the industry. Ongoing initiatives by the Financial Crimes Enforcement Network (FinCEN), and continued expansions of the federal examination procedures, reinforce the need to have a strong BSA program at your institution.
This manual covers in detail the issues and opportunities in the ever-expanding environment of the Bank Secrecy Act and reviews the entire realm of BSA from “A” to “Z”. From decades old Currency Transaction Reporting (CTR) and various recordkeeping requirements, to institutional risk assessment,
client due diligence (CDD), beneficial ownership expectations, and suspicious activity reporting, students from the novice appointee to the tenured BSA professional will find this manual to be of great value.
- Statutory and Regulatory Requirements
- Enforcement Actions and the “Lessons Learned”
- Acronym Review and Sources of Information
- USA PATRIOT Act Requirements and Implications
- Currency Transaction Reporting – FinCEN Form 112
- Exemption “Opportunities” From CTR Reporting
- Recordkeeping Requirements
- Office of Foreign Assets Control (OFAC)
- Culture of Compliance
- Implementing the Beneficial Ownership/Customer Due Diligence (CDD) program;
- Real Estate Title, Money Services Businesses (MSBs), Third-Party Payment Processors (TPPPs), “De-Risking”, and Other High-Risk Clients and Entities;
- Suspicious Transactions, Terrorist Financing, and other Money Laundering Techniques;
- Suspicious Activity Reporting (SAR) – Form 111
- SAR “Confidentiality”, Cyber-Related Events and Cyber-Related Crime, E-Mail Compromise Fraud, Human Smuggling and Human Trafficking; Marijuana Banking; Tax-Refund Fraud, “Vulnerable Adult” Exploitation;
- Institutional Risk Assessments;
- “High-Risk” Products, Services, and Geographies; and
- Federal BSA/AML Exam Expectations – Latest Updates
This manual is detailed with narrative explanations of regulatory requirements and examination procedures. The manual is an excellent resource for future reference.