Revised bank secrecy actantimoney laundering examination manual fil602014. See also bcbs 2010b, and bcbs 2014a consultative document on. Recent changes to the bsa examination manual will be noted, together with some practical ways you can raise bsa awareness among bank management and staff. Overview federal financial institutions examination council. Finra provides a template for small firms to assist them in fulfilling their responsibilities to establish the antimoney laundering aml compliance program required by the bank secrecy act bsa and its implementing regulations and finra rule 3310. Ffiec bsaaml appendices appendix j quantity of risk.
The strength of the language in the exam manual makes it easy to deduce that a comprehensive, risk based assessment will be the focal point of a banks bsa examination. Covered institutions should focus particularly on the manual s appendix k. Operations of foreign banking organizations 2003 rating system for u. The risk assessment should provide a comprehensive analysis of the. Current enforcement trends will be highlighted and new and emerging areas of risk will be discussed. Like any other business line at a regulated examiners should assess the credit union, effectiveness of program governance, the risk management framework, operational procedures, and. Confirm that credit union conducts a risk assessment of wire transfers and acts in accordance with the findings of the assessment. According to ncua, credit unions must use a risk based approach when developing their programs. Get answers the latest discussions in the cbanc community. Does anyone have a template for an ofac risk assessment. Federal financial institutions examination council ffiec bsa aml examination manual opens new window. In a recent exam by the ncua we were told that our bsa risk assessment is outdated for our current size. Risk assessment for financial institutions carr, riggs. The msb bsa aml self assessment tool is not a requirement msbs should not feel obligated to performing the self assessment.
Ffiec bsa aml examination manual 3 05052018 examiners should primarily focus on whether the bank has effective processes to develop customer risk profiles as part of the overall cdd program. Examination resources examination manuals and guidance. Riskbased approach guidance for the banking sector fatf. Foremost is the ffiecs bsa aml examination manual, available on the ffiec website ffiec. However, the answers are not meant to be comprehensive, apply to all factual situations, or to replacesupersede the bsa regulations. Core examination procedures for assessing the bsaaml compliance program. Bank secrecy actantimoney laundering bsa aml office of foreign assets control ofac. Operations 2002 examination planning and the assessment of the u. Note 1 the mp3 files may not be complete copies of the pdf files due to the exclusion of charts and tables that do not convert well to audio presentations. Several resources are available to institutions seeking to ensure compliance in this area.
For these reasons, management should not limit the risk assessment process to risks associated with specific platform s, their operating system s, resident. These examination procedures are for banking lcblicensed marijuana related credit unions businesses. Bank secrecy act antimoney laundering examination manual. The cip must contain risk based procedures for verifying the identity of the customer within a reasonable period of time after the account is opened. How to perform a financial institution risk assessment. It operations comprise the framework of service and product delivery to internal and external customers and are intrinsic to much of the risk management undertaken by the institution. This bsa aml self assessment tool assessment tool is voluntary and may be used at your institutions discretion. The msb bsa aml self assessment tool is not a substitute for a risk assessment institutions that choose to use this self assessment tool should use it in addition to the fincen bsa aml examination manual.
Bsaaml selfassessment tool overview and instructions. Whatever format management chooses to use for its risk assessment. The management booklet of the ffiec1 it examination handbook and the ffiec bank secrecy actantimoney laundering bsa aml examination manual provide highlevel descriptions of risk management processes that include planning, risk identification and assessment, controls, and. Bank secrecy actantimoney laundering examination manual for. This booklet addresses compliance banks with the secure and fair enforcement for mortgage licensing safe act of 2008, which mandates a nationwide licensing and registration system for residential mortgage loan originators. Bsa summary and ofac risk assessment considerations of nov. Csbs and a group of state bsa aml subjectmatter experts developed the bsaaml self assessment tool to be used at the discretion of a financial institution to help in the bsa aml risk assessment process. Bank secrecy actantimoney laundering examination manual. Bsa aml examination manual was revised in april 2010, ffiec replaced the phrase high risk customer with higher risk customer throughout the manual to avoid this type of confusion. It is flexible and intended to be adapted to each institutions circumstances and risk profile. Bank secrecy act bsaantimoney laundering aml examination.
Branches and agencies of foreign banking organizations 2010 risk focused approach to pre examination planning 2020 loan sampling. For more information on bsa aml risk assessments for small msbs, please see the references and resources provided with this article. Determine whether the bank has included all risk areas, including any new products, services, or customers, entities, and geographic locations. One of the provisions is that covered financial institutions are required to establish and maintain written procedures that are reasonably designed to identify and verify beneficial owners of legal entity customers and.
The sections of the ffiec bsaaml examination manual that have been added or significantly. He stressed the four elements of an effective bsa program. Ffiec bsaaml compliance program bsaaml risk assessment. The revised federal financial institutions examinations councils ffiec bsa aml examination manual states that a financial institutions risk assessment.
An introduction to the ffiec bsa aml examination manual and related concepts. The publications below provide guidance to officials examining money services businesses msbs for compliance with the requirements of the bank secrecy act bsa. December 31, 2008, and the next renewal must be filed by december 31, 2010. Bsa aml examination manual section list and download options. Revised ffiec bank secrecy actantimoney laundering examination manual and infobase fil732007.
For example, if the examiner determines that a money transmitter may. The bsa aml self assessment tool is not a substitute for a risk assessment institutions that choose to use this self assessment tool should use it in addition to the ffiec bsa aml examination manual1 and corresponding laws and regulations, not as a replacement. Its been nearly half a decade since the ffiec and fincen have released a new update of the bsa aml examination manual. Sample msb examination manual work program december 2008 pdf only. Joint statement on risk focused bsa aml supervision opens new window sharing bsa resources opens.
Related to these is a form made available by the occ. Appendix i risk assessment link to the bsaaml compliance program. On page 57 of the bsa aml examination manual published in february 2015, the title of the section is enhanced due diligence for higher risk customer. Bank secrecy act antimoney 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, office of thrift supervision, and state liaison committee 2010. In this video, affirmxs senior analyst, coppelia padgett, provides an. Bank secrecy act bsa and related rules and regulations. The may 11, 2016, final rule on customer due diligence cdd requirements created an entirely new section, 31 cfr 1010. Bank secrecy actantimoney laundering examination manual for money services businesses examination procedures 29 preplanning the bsa examination 29 preplan procedures 29 risk assessment 32 developing a risk based examination plan 32 transaction testing plan 33 msb registration requirements overview 34 msb agent list 35 examination procedures 37 msb. This is one more risk assessment tool being distributed to national banks as part of the occs exam process. Rmlos risk categories and provide a detailed analysis to assess the level of risk.
Revisions to the ffiec bsaaml manual to include the new. Ffiec it examination handbook infobase risk assessment. Ffiec aml examination manual february 2015, available at. Evaluating the bsa aml risk assessment should be part of scoping and planning the examination, and the inclusion of a section on risk assessment in the manual does not mean the two processes are separate.
Manual provides guidance on risk assessments, with examples. For more information about bsa compliance, see the ffiecs bsa antimoney laundering examination manual. Prior to using this matrix, they should complete the identification and quantification steps detailed in the bsa aml risk assessment overview section at page 18 of this manual. Assessing the bsa aml compliance program and address areas such as scoping and planning and the bsa aml risk assessment and compliance program regulatory requirements and related topics which include the customer identification program, customer due diligence, suspicious activity reporting, funds transfers recordkeeping. Therefore, the content in the pdf version takes precedence over the content in the audio version. This rescission applies to the transmitting document only and. The graphic below from the ffiec bsaaml examination manual4.
Bsa risk assessment compliance risk bsaaml risk assessment. In fact, the ffiec bsa aml examination manual emphasizes that examiners evaluate the financial institutions risk assessment as part of the planning and scoping phase of the examination. National exam risk alert mastersub accounts september 29, 2011. The following lists provide the steps for creating a risk assessment and the reasons each category presents. Bsaaml examination manual section list and download options. Document library a searchable, sortable archive of the documents uploaded to cbanc. Acams risk assessment provides an automated means of measuring, understanding and explaining an institutions money laundering risks.
Also on the panel was john wagner, occs new director for bsa. Regulator panel 04152018final west coast antimoney. Bsa summary and ofac risk assessment considerations of nov 2009 pub aug 2010. Bank secrecy act antimoney laundering examination manual for money services businesses december 2008 pdf only. The online link under view allows you to see the selected section online or by selecting pdf under download you can print or save the selected section. The bank secrecy act antimoney laundering examination manual. Each institution can utilize these tools along with other resources, such as the new ffiec manual, to design your own customized program. The online link under view allows you to see the selected section online or by selecting pdf under download you. The ncua has provides resources and links to information to help credit unions comply with the bank secrecy act skip to main content.
The template provides text examples, instructions, relevant rules and websites and other resources that are useful for. Banks and examiners may use the following matrix to formulate summary conclusions. The bank secrecy act bsa, initially adopted in 1970, establishes. To view specific sections of the manual, select within the left column. In essence, the bsa aml risk assessment is viewed as a roadmap for understanding the banks risk profile and thereby providing the foundation for. The following information gathered was utilized as a guide to determine what information should be included in the new risk assessment. Bsaaml risk assessment for money services businesses msbs. Based on its risk assessment, a bank may require identifying information in addition to the items above for certain customers or product lines. Guidance to examiners on examination scoping and planning, assessing the bsa risk assessment and compliance program, and developing conclusions and finalizing the exam. Assess the bsa aml risk profile of the bank and evaluate the adequacy of the banks bsa aml risk assessment process.
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