BSA Flashcards
The BSA program requirements are
Must be in writing
Approved by board of directors and noted in the board minutes
Must be commensurate with instruction BSA profile ( Products, Services, customers, entities,an geographies served)
Content of BSA program should include
System of of internal controls
Independent testing for compliance
Designated individual responsible for coordinating and monitoring on day to day basis
System for training employees
What should system of controls provide
Identification of vulnerable to money laundering
Inform board of directors and senior management of compliance
Identify person to ensure compliance
For currency more than 10k, financial institutions must file
A Fincen bank secrecy act currency transaction report. (BCTR)
What transactions BCTR be filed on
Deposits
Withdrawals
Currency exchange
Payment or transfer through a financial institution
CTR must be filed in how many days
15 after the reportable transaction occurred
How are CTRs filed
Through ficen bsa e filing system
How must a bank designate someone as exempt from filing an ctr
Filing a ficen form 110 within 30 days of the first reportable transaction
How often must a person exempt status be reviewed
Annually
What must banks do when they consider someone to be exempt
Make sure the necessary steps were taken
Document the basis for its conclusions
And reason for compliance
Are listed businesses exempt from ctr reporting
Yes,
Are subsidiary of listed businesses exempt from ctr
Yes
When does a bank subject to a penalty for failure to file a CTR on a exempt transaction
Knowingly Filed a false report
The transaction did not meet the exempt criteria
When can a business lose an exempt status
Comes off stock exchage
If a subsidiary and parent company owns less than 51%
Suspicious activity
When do you have to file a report of international transportation of currency or monetary instruments (cmir)
When exporting more than 10k out of the country and you are not exempt
When must a cmir be filed
If sending one, at the time of entry into the us
If receiving one, 15 days after receipt
Who has to report a foreign financial account
Any person with a financial interest in or has authority over a financial account in a foreign country
Reporting foreign accounts must be made using
Ficen form 114
If a person had 25 or more accounts, do they have to file detail information on each one
No
If the amount of the foreign account exceeds 10k, how soon does the report have to be filed
Therefore 6/30 of the proceeding year
What must be maintained for purchasers of money orders 3k or more
Name of purchaser Date of purchase Type of instrument Serial number of each instrument Dollar amount of each instrument Verification of customer identity
Are fund transfers monitored under BSA
Yes ,3k or more and the transfer does not state a condition of payment
What type of fund transfers do not have to be reported
Clearing house, atm, point of sale, ones originated at a bank, us, state or local government, broker
