BSA
The Bank Secrecy Act Officer
Who is Jennifer McIntosh?
This is the dollar threshold that triggers requirement to file a Currency Transaction Report (CTR)
What is $10,000.01?
All transactions, in aggregate, conducted by or on behalf of the same person in excess of $10,000 require a CTR filing.
The bank must maintain record for each bank check or draft, cashier's check, money order or traveler's check it sells or issues for this amount or more in cash
What is $3,000?
Name, Current address, Tax Identification Number, Birthdate, OFAC scan.
What are the 5 required pieces of information for CIP to open an account?
Bonus Info:
The address for mailing can be a P.O. Box but we must obtain a physical address for BSA records.
See CIP Policy for information on acceptable forms of documentary and non-documentary identification.
True or False: It is permissible to notify a customer that a SAR is being filed on them.
What is False?
The fact that a SAR has been filed is strictly confidential. Even law enforcement is not allowed to ask whether we filed a SAR. They have access to a database where they can obtain that information. They CAN request the case file for the SAR, which must be accompanied by a judicial subpoena or other court order.
The new system are we using to help with BSA
What is Verafin?
Customers who may be exempted from CTR reporting by filing this form with FinCEN.
What is a Designation of Exempt Person form?
A review is conducted by the BSA Officer annually thereafter to make sure the entity still qualifies for exemption.
True or False: If a customer purchases a cashier's check for $10,500, we do not need to run OFAC on the Payee if they are customer.
What is True?
How long must we retain identification/documents after an account has been closed?
(Hint: Between 2-6 years)
5 years
What are examples of reasons we may file a SAR?
Insider abuse by an employee (any amount)
Violations of law aggregating over $5,000 or more where a subject can be identified and over $25,000 or more regardless of a potential subject
Identity Theft (any amount)
Transactions aggregating $5,000 or more that involve potential money laundering or violations of the Bank Secrecy Act
Computer intrusion (any dollar amount)
When we have direct knowledge that a customer is operating as an unlicensed money services business.
True or False? It is permissible to conduct business with someone on the OFAC list.
What is False?
The bank has this many calendar days after the "business day" the reportable cash transaction occurred to electronically file a CTR
What is 15 calendar days?
True or False: The bank sells Cashier's check to non-account holders.
What is False?
Must have a birthdate, a photograph, and an issue date.
What is required information on a government issued, non-expired identification?
True or False: When you notice something that seems suspicious, you should keep it to yourself until you have more details. You don't want to draw attention to it until you have all the facts.
What is False?
Bonus Info:
Suspicious can be anything that doesn't seem right or gives you an uneasy feeling about the transaction or the customer.
True or False
It is acceptable to help a customer arrange a transaction to avoid BSA reporting requirements.
What is False?
True or False:
A customer cashes a check for $15,000. Later that same day, he returns to the bank and deposits $12,000 in cash to his checking account. No CTR would be required because the net cash received by the customer at the end of the day is only $3,000
What is False?
When aggregating transactions for CTR filing we add deposits to deposits and withdrawals to withdrawals but we do not "net out" that number for CTR determination.
True or False: A purchase of a cashier's check with $12,000 in cash requires a CTR filing.
What is True?
Piece of postmarked mail received at current address, utility bill, apartment lease.
For CIP discrepancy purposes does it prove where the customer lives?
What is the Suspicious Activity Referral Form to the BSA Officer?
How do we internally report "suspicious" activity?
The suspicious activity form is located on SharePoint You may send it electronically or in paper form sealed in an envelope to the BSA Officer.
THE PROCESS OF PLACING, LAYERING, AND INTEGRATING FUNDS TO CHANGE ILLEGAL/DIRTY FUNDS TO LAUNDERED/CLEAN FUNDS
What is Money Laundering?
Placement = dirty money into the FI
Layering = transfers, wires, prepaid devices
Integration = purchase of luxury assets, financial investments
True or False: A CTR is required for an even up cash exchange
A customer comes in with $11,000 in odd bills and exchanges them for $20s.
What is True?
Currency exchanges in excess of $10,000 require a CTR filing.
This is the name of the method of money laundering in which negotiable instruments were purchased for cash below the currency transaction reporting threshold
What is structuring or smurfing?
What are the 4 pieces of identifying information required to open an account?
What is 1. Legal Name. 2. Date of Birth. 3. Physical Address. 4. Taxpayer Identification Number.
This is the number of calendar days that the bank has to file a SAR once suspicious activity has been detected.
What is 30?