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Designating an individual to be responsible for overseeing the BSA program
Providing annual training for all employees as well as the Board of Directors
Testing of internal controls
Advertising or notifying the public that the bank is in compliance with the BSA requirements
Monitor, Advise and Document
Assess, Document, and Inform
Detect, Deter and Report
Question, Follow-Through and Enforce
Terrorist transactions are often not complex and do not involve large sums of money
Terrorist often finance their activities through both legitimate and unlawful sources
Terrorists do not use the same money laundering techniques as other criminals use
Terrorists do not open bank accounts so banks do not have to be concerned about them
A method of independent testing that is conducted to locate funding of criminal activities.
The criminal practice of filtering money through a bank and involves placement, layering and integration.
Another name for check fraud and wire scams.
Removing damaged or "dirty" cash from circulation.
File Currency Transaction Reports for cash transactions over $10,000.
File Suspicious Activity Reports for any transaction that appears suspicious.
Keep all BSA records for a period of at least five years
Form a reasonable belief as to the identity of customers at account opening
Conduct a follow-up call with clients after a CTR has been filed.
Cease and Desist Orders
Restrictions on mergers, acquisitions and branching
Terminate institutions deposit insurance
Personal fines and jail time for employees, and Officers of the bank
Restrict new account openings and deposit amounts
Customer Identification Program (CIP)
USA Patriot Act
Open the account and ask them to produce more proof in a 24 hour period.
Contact your Manager to approve opening the account
Do not open the account and provide an adverse action notice
Open the account but place a warning on the system and holds on all deposits until a relationship is established
Wire transfers of $1,000 or more
Currency transactions exceeding $5,000
Negotiable instrument sales for cash in amounts of $3,000 to $10,000
List of individuals in the US illegally
A new customer deposits $7,500 cash in a Money Market account and $500 cash into a checking account
A well established customer makes three separate cash deposits on the same day at three different locations. A $4,570 deposit into a savings account, $4,020 into a Money Market account and $1,120 into a regular checking account.
A customer deposits a $5,000 check, a $4,000 check and $7,000 cash into the same account.
A business owner deposits $5,000 cash in the night depository and comes in later that same day to deposit $6,202 in cash to a different account.
Teller or employee conducting the transaction
BSA or Alternate BSA Officer
Manager of the location where the transaction took place
The customer is unknown at the bank
The amount of the transaction is reduced by the customer to avoid a CTR
Customer leaves the bank angry because ID was requested to cash a check
Amount of transaction is over $10,000 in cash
Why the report is being completed for this particular transaction
What the BSA requirement is for completing the report
How completing the report will/will not affect the transaction
Explain how the report helps to catch criminal activities
Exemptions must be reviewed annually for exemption renewal
BSA Officer must approve and review exemption requests
Auto Sales and Leasing is an eligible business for exemption
Customer must have a "transaction account"