BSA/Anti-Money Laundering: Internal Audit and Risk Management

Written by financial institution consultant Dena Somers, this guide provides information to help your financial institution establish and implement risk-based policies, procedures, and processes to comply with the most recent regulatory release of the BSA/AML Examination Manual. It also contains the latest information on topics such as electronic banking, changes to BSA reporting requirements, and OFAC compliance.

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The regulators are placing more emphasis on BSA/AML compliance than ever before. Examinations focus on your organization’s responsibility to establish and implement risk-based policies, procedures, and processes to comply with the Bank Secrecy Act and safeguard your operations from money-laundering and terrorist-financing. Be ready for the most recent changes in the examiners’ approach to BSA compliance with Sheshunoff®'s BSA/Anti-Money Laundering: Internal Audit and Risk Management manual.

This comprehensive resource takes the examination guidelines and interprets them for you, providing specific actions to ensure that all of your policies, procedures, and processes are risk-based. The manual focuses on all the issues on which examiners will be concentrating, so you can be sure that your institution is well prepared for your next examination.

Sheshunoff®'s BSA/Anti-Money Laundering: Internal Audit and Risk Management manual will give you the guidance and tools you need to help your financial institution:

•  Comply with the latest regulatory release of the Bank Secrecy Act/Anti-Money Laundering Examination Manual.
•  Focus on risk management and audit requirements emphasized in the new regulatory release.
•  Ensure that all of your institution’s BSA/AML policies and procedures are based on assessing its specific risks.
•  Prepare for your next BSA/AML examination.

This up-to-date resource includes information on the latest topics such as remote deposit capture, consolidated risk assessments, electronic banking and new BSA issues, smart cards, recent enforcement actions, red flags for money laundering, and providing banking services to money service businesses. Internal control and transaction testing checklists in many of the chapters help you tailor procedures to the specific needs of your institution.

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Table of contents

Part I — Audit Planning for Risk Management

Chapter 1 BSA/AML Examinations

Chapter 2 Preparing for the Risk-Based Audit

Part II — Audit Procedures for BSA/Compliance Program

Chapter 3 BSA/AML Compliance Program Audit

Chapter 4 Customer Identification Program Audit

Part III — Audit Procedures for Specific Regulatory Requirements

Chapter 5 Customer Due Diligence (CDD)

Chapter 6 Suspicious Activity Reporting

Chapter 7 Currency Transaction Reports and Exemptions

Chapter 8 Information Sharing — Section 314(a) and (b)

Chapter 9 Purchase and Sale of Monetary Instruments

Chapter 10 Funds Transfers

Chapter 11 International Banking

Chapter 12 Foreign Bank and Financial Accounts Reporting and International Transportation
of Currency or Monetary Instruments Reporting

Chapter 13 The Office of Foreign Assets Control (OFAC)

Chapter 14 Special Measures Under Section 311 of the USA PATRIOT Act

Part IV — Audit Procedures for Specific Products and Services

Chapter 15 Domestic Correspondent Accounts

Chapter 16 Foreign Branches and Offices of U.S. Financial Institutions

Chapter 17 Electronic Banking

Chapter 18 Deposit and Nondeposit Products

Chapter 19 Concentration Accounts

Chapter 20 Lending Activities

Chapter 21 Trust and Asset Management Services

Part V — Audit Procedures/Risk Factors for Specific Persons and Entities

Chapter 22 Specific Persons and Entities



Appendix A 31 CFR
Chapter X (with Annotated Cross-Reference Guide)

Appendix B 31 USC
Chapter 53

Appendix C FIL-32-2005 — Interpretive Guidance on Providing Banking Services to Money
Services Businesses Operating in the United States

Appendix D GAO Report: Company Formations — Minimal Ownership Information Is
Collected and Available

Appendix E FinCEN Guidance on Obtaining and Retaining Beneficial Ownership

Appendix F FinCEN Advisory to Financial Institutions on Filing Suspicious Activity Reports
Regarding Trade-Based Money Laundering

Appendix G FAQs About 31 CFR
Chapter X