BSA/AML Introduction Flashcards
What is Money Laundering?
Process of illegally gained funds through a legitimate source
What are the 3 Stages of Money Laundering?
Placement- Intro of funds
Layering- Movement of funds
Integration- Putting the funds back into the economy
Describe the Bank Secrecy Act (1970)
This required banks to assist the U.S. government to detect and prevent money laundering by reporting cash transactions over 10,000 - filing a CTR report, and reporting suspicious activity, by filing a SAR
Describe the USA Patriot Act (2001)
Came about after 9/11, Purpose is to unite and strengthen US by providing the appropriate tools required to intercept and obstruct terrorism
Describe Section 352:
Requires that AML Programs at a minimum MUST include:
Internal Policies and Procedures
Designation of a Compliance Officer
Ongoing Employee Training Program
Independent Audit Program
What is the difference between 314 a & b?
314A is for law enforcement agencies to communicate the names of suspected money launderers to financial institutions, 314B is for financial institutions to communicate the names of money launderers between each other
What is Section 326?
This is the Customer Identification Program
What are the CIP MINIMUM requirements?
Name, DOB, SSN, Address
What is FINCEN?
Financial Crimes Enforcement Network
- Department of the US Treasury
- Serves as FIU for the US
- Collect, analyze and disseminate BSA information
What is OFAC?
Office of Foreign Assets Control
-Department of US Treasury
-Administers and enforces economic trade sanctions
What is the SDN List?
Specially Designated National List (Non Proliferation Sanction, Global Magnitsky Sanction, Counter narcotic trafficking sanctions
What is FATF?
Financial Action Task Force
International. Leads global action to prevent money laundering and terrorist and proliferation financing
What is ACAMS?
Association of Certified Anti Money Laundering Specialists
Largest international membership organization dedicated to enhancing the
knowledge and expertise of financial crime detection and prevention
professionals
What are the pillars of BSA?
1) Internal Controls
2) Independent Testing
3) BSA Compliance Officer
4) Training
5) CDD- Customer Due Diligence
What is CDD?
Customer Due Diligence- Getting more INFO- Business/ occupation
source of funds for the account
PURPOSE of the account
expected activity for the account
Beneficial ownership