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