Help For Your BSA Exam

The Examination Procedures from the Federal Reserve Board of Governors has been distributed. Called the "Workprogram", it is part of a larger package, named the "Federal Reserve's Bank Secrecy Act Examination Manual". It has a long checklist that the auditor or compliance officer can use to be sure you are up to speed for your BSA exam. We are including part of the checklist, in very abbreviated form, in this issue. We will continue the list, as space permits, in other issues so that you will have the whole recommended program. We think you'll understand all our "short forms", used in the interest of space. All questions are "Yes", "No", or "Not Applicable" answers, with "No" answers requiring an explanation?in other words-fix 'em! Questions with a "*" indicate examiner response-not yours. Good Luck!

Previous exam OK?
If not, corrective action taken?
Internal controls and audit procedures in areas other than BSA OK in previous exam?
Information on institution on criminal referral database?*
Change in volume of CTRs for institution??for branch?
Cash flow reports available?? any unusual trends?

Internal Compliance Programs & Procedures
Internal compliance programs & procedures in place as of previous exam?
Written compliance program?
Does written program contain:
a) internal controls to ensure ongoing compliance?
b) independent testing by bank personnel or outside? Name?
c) employee responsible for coordinating and monitoring day-to-day? Name and qualifications (i.e. training, experience)
d) training?
Compliance program approved by Board?
Does program have procedural guidelines for reporting and recordkeeping requirements of BSA?? and does it provide for:
a) ALL over $10,000 transactions? b) centralized list of exemptions? with supporting information?
c) 4790 filings (if applicable)
d) Report of Foreign Bank Financial Accounts Form 90-22.1, if applicable
e) required records for monetary instrument sales-$3,000 to $10,000
In procedural guidelines, provision for five year of records for:
a) each CTR?
b) exemption documentation?? and a requirement to keep records 5 years from the date it was discontinued?
c) each extension of credit over $10,000? (except where secured by real property)
d) each advice, request, or instruction for transfer of funds of more than $10,000 outside U.S.?
e) same information as (d) on correspondents?
f) list of all accounts with no taxpayer ID?
g) signature authority on each deposit account?
h) statements, ledger card, or other record showing each transaction?
i) all records on transactions over $10,000 transferred out of U.S.?
j) each check/draft over $10,000 drawn on foreign bank which the domestic bank has paid or presented to a nonbank drawee for payment?
k) each item more than $10,000 received directly from a bank, broker, or dealer in foreign exchange outside U.S.?
l) records necessary to reconstruct a DDA & to trace a deposited check over $100?
m) name, address, taxpayer ID of presenter of a CD for payment, with description of CD and date of transaction?
n) each deposit slip (showing any currency involved) with transactions over $100, or equivalent record for direct deposit or wire transfer deposit?