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Inactive Financial Institution Letters


An examination of your Bank Secrecy Act (BSA) compliance program will be conducted. Please provide the information below for the pre-examination portion of the examination, or note which items do not apply to your bank.

PRE-EXAMINATION (OFFSITE) BSA REQUEST LIST


___Name and title of individual(s) responsible for monitoring Bank Secrecy Act/anti-money laundering (AML) activities and handling Section 314(a) information requests.
___Copy of management’s AML risk assessment of all major business lines, products, and services.
___Completed BSA Officer’s Questionnaire.
___Copy of most recent Board approved BSA/AML policy and procedures.
___Copy of most recent Board approved Customer Identification Program.
___Copy of policy and procedures relating to Office of Foreign Asset Control (OFAC) sanctions.
___Copy of policy and procedures relating to Suspicious Activity Report (SAR) reporting and monitoring requirements.
___Copy of procedures/program to comply with the USA PATRIOT Act Section 314(a) information requests.
___Copy of most recent independent audit results for BSA/AML/OFAC compliance (internal and/or external sources), including management’s responses.
___Copy of latest listing of accounts without taxpayer identification numbers (TINs).

EXAMINATION (ONSITE) BSA REQUEST LIST

An examination of your Bank Secrecy Act (BSA) compliance program will be conducted. Please have the following information ready on the first morning the examination begins onsite, or note which items do not apply to your bank. Provide copies of information only in those instances where specifically requested.

___Copy of BSA/AML/OFAC training schedule with dates, attendees, and topics.
___Designation of Exempt Person Forms for current exemptions.
___Exemption files containing documentation supporting exemptions (cash history, etc.).
___Bank-specific correspondence received from the Treasury (Financial Crimes Enforcement Network, Detroit Computing Center, Office of Foreign Asset Control, etc.) since the previous BSA examination.
___File of correspondence requesting taxpayer identification numbers (TINs).
___Log or other method used to retain required information on the purchase of monetary instruments for cash in amounts of $3,000 to $10,000.
___Training file (for example, materials used for training since the previous BSA examination).
___Record retention schedule and procedural guidelines.
___File of Forms 4789 Currency Transaction Reports (CTRs).
___File of Forms 4790 Report of International Transportation of Currency or Monetary Instruments (CMIR).
___File of Forms 90-22.1 for interest in foreign bank accounts.
___File of SARs.
___Logs reflecting cash shipped to and received from the Federal Reserve Bank, correspondent banks, or between branches for the previous six months.
___Correspondence file with federal law enforcement authorities concerning disposition of accounts reported for suspicious activity.
___Reports used by the bank to detect suspicious transactions, such as the suspected kiting report, demand deposit activity report, large cash transaction report, currency aggregation report, and a report of loans secured by cash collateral.
___Logs or other method reflecting incoming and outgoing wire transfers.
___Description of the types and volume of wire transfer activities conducted by the bank. Include methods of payment accepted for such transfers and also acceptable remitters (for example, accountholders versus non-accountholders).
___Listing of all payable through demand deposit relationships with foreign financial institutions.
___If applicable, contract/agreement with foreign financial institutions that have payable through accounts.
___If applicable, policies concerning payable through accounts (may be in BSA Policy).
___If applicable, policies and procedures for private banking accounts.
___A description of the types of transactions received via “pouch,” (for example, common courier or messenger) from abroad and the bank’s process for monitoring such activity.
___Logs used to identify transactions received via “pouch.”
___If applicable, documentation to evidence compliance with 31 CFR Section 103.177 and 103.185 (for foreign correspondent accounts).
___A listing of all loans secured by cash collateral which have defaulted since the previous BSA examination, including those charged off.
___Contracts with financial institutions and with third parties that perform all or any part of the bank’s Customer Identification Program (CIP).
Last Updated 08/15/2004 communications@fdic.gov