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Bank Secrecy Act/Anti-Money Laundering Examination Manual

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Bank Secrecy Act/Anti-Money Laundering Examination Manual Bank Secrecy Act / Anti-Money Laundering Examination Manual Federal Financial Institutions Examination Council: Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, Office of the Comptroller of the Currency, and Office of Thrift Supervision 2006 Table of Contents The sections of the FFIEC BSA/AML Examination Manual that have been added or significantly modified from the previous edition are reflected by date. INTRODUCTION ........................................................................................................... 1 CORE EXAMINATION OVERVIEW AND PROCEDURES FOR ASSESSING THE BSA/AML COMPLIANCE PROGRAM......................................................................... 11 Scoping and Planning — Overview (2006).............................................................. 11 Examination Procedures (2006)............................................................................ 15 BSA/AML Risk Assessment — Overview (2006) ................................................... 18 Examination Procedures (2006)............................................................................ 27 BSA/AML Compliance Program — Overview (2006) ............................................ 28 Examination Procedures (2006)............................................................................ 34 Developing Conclusions and Finalizing the Examination — Overview (2006) ...... 40 Examination Procedures (2006)............................................................................ 41 CORE EXAMINATION OVERVIEW AND PROCEDURES FOR REGULATORY REQUIREMENTS AND RELATED TOPICS ............................................................... 45 Customer Identification Program — Overview........................................................ 45 Examination Procedures ....................................................................................... 52 Customer Due Diligence — Overview..................................................................... 56 Examination Procedures ....................................................................................... 59 Suspicious Activity Reporting — Overview (2006)................................................. 60 Examination Procedures ....................................................................................... 71 Currency Transaction Reporting — Overview......................................................... 76 Examination Procedures ....................................................................................... 78 Currency Transaction Reporting Exemptions — Overview..................................... 80 Examination Procedures ....................................................................................... 84 Information Sharing — Overview (2006)................................................................. 86 Examination Procedures ....................................................................................... 91 Purchase and Sale of Monetary Instruments Recordkeeping — Overview.............. 94 Examination Procedures ....................................................................................... 97 Funds Transfers Recordkeeping — Overview.......................................................... 98 Examination Procedures ..................................................................................... 104 Foreign Correspondent Account Recordkeeping and Due Diligence — Overview (2006)..................................................................................................... 105 Examination Procedures (2006).......................................................................... 113 Private Banking Due Diligence Program (Non-U.S. Persons) — Overview (2006)..................................................................................................... 118 Examination Procedures (2006).......................................................................... 123 Special Measures — Overview............................................................................... 126 Examination Procedures ..................................................................................... 129 Foreign Bank and Financial Accounts Reporting — Overview ............................ 130 Examination Procedures ..................................................................................... 131 International Transportation of Currency or Monetary Instruments Reporting — Overview................................................................................................................. 132 Examination Procedures ..................................................................................... 134 Office of Foreign Assets Control — Overview (2006) .......................................... 135 FFIEC BSA/AML Examination Manual i 7/28/2006 Table of Contents Examination Procedures (2006).......................................................................... 144 EXPANDED EXAMINATION OVERVIEW AND PROCEDURES FOR AN ENTERPRISE-WIDE COMPLIANCE PROGRAM AND OTHER STRUCTURES .... 147 Enterprise-Wide BSA/AML Compliance Program — Overview (2006)............... 147 Examination Procedures (2006).......................................................................... 151 Foreign Branches and Offices of U.S. Banks — Overview ................................... 154 Examination Procedures ..................................................................................... 158 Parallel Banking — Overview................................................................................ 160 Examination Procedures ..................................................................................... 161 EXPANDED EXAMINATION OVERVIEW AND PROCEDURES FOR PRODUCTS AND SERVICES.......................................................................................................... 163 Correspondent Accounts (Domestic) — Overview ............................................... 163 Examination Procedures ..................................................................................... 166 Correspondent Accounts (Foreign) — Overview................................................... 168 Examination Procedures ..................................................................................... 171 U.S. Dollar Drafts — Overview ............................................................................. 173 Examination Procedures ..................................................................................... 174 Payable Through Accounts — Overview ............................................................... 176 Examination Procedures ..................................................................................... 179 Pouch Activities — Overview ................................................................................ 182 Examination Procedures ..................................................................................... 184 Electronic Banking — Overview ........................................................................... 186 Examination Procedures ..................................................................................... 188 Funds Transfers — Overview................................................................................. 189 Examination Procedures ..................................................................................... 194 Automated Clearing House Transactions — Overview (2006).............................. 196 Examination Procedures (2006).......................................................................... 200 Electronic Cash — Overview (2006)...................................................................... 202 Examination Procedures ..................................................................................... 204 Third-Party Payment Processors — Overview....................................................... 205 Examination Procedures ..................................................................................... 207 Purchase and Sale of Monetary Instruments — Overview..................................... 208 Examination Procedures ..................................................................................... 209 Brokered Deposits — Overview............................................................................. 211 Examination Procedures ..................................................................................... 213 Privately Owned Automated Teller Machines — Overview.................................. 215 Examination Procedures ..................................................................................... 218 Nondeposit Investment Products — Overview....................................................... 220 Examination Procedures ..................................................................................... 225 Insurance — Overview (2006)................................................................................ 227 Examination Procedures ..................................................................................... 230 Concentration Accounts — Overview.................................................................... 232 Examination Procedures ..................................................................................... 234 Lending Activities — Overview............................................................................. 235 Examination Procedures ....................................................................................
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