BSA
BANK SECRECY ACT ACRONYM
WHAT IS BSA
The purpose behind BSA/AML is to stop money laundering, terrorist financing and other illegal activities
CTR STAND FOR WHAT
WHAT IS CURRENCY TRANSACTION REPORT.
These reports are filed with FinCEN for tracing the flow of currency through the financial system helps identify the "unusual"
SAR STANDS FOR
WHAT IS SUSPICIOUS ACTIVITY REPORT
When the "unusual" is identified, investigated and deemed "suspicious"
Terrorist financing, Tax evasion, Elder abuse, Identity theft, Fraud, Account takeovers, Human trafficking, Smuggling, Funnel account activity, Structuring to avoid reporting.
We are not investigating or accusing of a crime, just notifying authorities of account activity and explaining why that activity is unusual or suspicious
AML stand for
What is Anti-Money Laundering
A set of procedures, laws and regulations designed to stop and practice of generating income through illegal actions.
CAN A BANK THAT VIOLATES CERTAIN BSA PROVISIONS INCLUDING 31 USC 5318(I) OR (J) OR SPECIAL MEASURES BE IMPOSEDPENALTIES? YES OR NO UNDER 31 USC 5318 A FACES CRIMANAL MONEY PENALTIES UP TO THE GREATER OR $1 MILLION OR TWICE THE VALUE OF THE TRANSACTION
What is Yes
UNDER 31 USC 5318 A bank can face criminal money penalties up to the greater or $1 million or twice the value of the transaction
THE PROCESS OF PLACING, LAYERING, AND INTEGRATION OF FUNDS.
WHAT IS MONEY LAUNDERING
Placement= dirty money into the FI
Layering= transfers, wires,
Integration= purchase of luxury assets, financial investments
CTR'S ARE REQUIRED FOR ANY CASH TRANSACTION IN EXCESS OF.
WHAT IS $10,000
Cash in or out in one business day that exceeds $10,000 on behalf of, or transacted by, the same person. Multiple transactions must be aggregated.
A SAR MUST BE FILED WHEN THERE IS INSIDER ABUSE INVOLVED, REGARDLESS OF THE AMOUNT. TRUE OR FALSE?
WHAT IS TRUE
Insider abuse= Zero tolerance
Suspect can be identified= transaction aggregation $5,000 or more
Potential Suspect= transaction aggregation $25,000 or more
Can file for lower amount- Safe Harbor
MONETARY INSTRUMENT REPORTS ARE REQUIRED ON SALES OF MONETARY INSTRUMENTS SOLD FOR CASH IN AMOUNTS FROM ______ TO $10,000
WHAT IS $3,000
Monetary instruments = cashier's check's, money orders, Cash Advances and prepaid cards. Must record when a purchased with cash between $3,000 and $10,000. This log is kept by compliance.
If you save the report to the BSA Monetary and Cash Adv Logs folder, Patricia will not call you.
LARGE, FREQUENT OR UNEXPECTED WITHDRAWALS, TRANSFERS BETWEEN ACCOUNTS THE CUSTOMER CANNOT EXPLAIN. NEW OR UNINVITED HELPERS. CONFUSION FEAR OR LACK OF AWARENESS, SUSPICIOUS SIGNATURES, UNCHARACTEISTIC WIRE TRANSFERS, SUDDEN NON SUFFICENT FUNDS OR LATE PAYMENTS, CHECKS WRITTEN AS LOANS OR GIFTS, ARE ALL SIGNES OF ___________ ________
What is Elder Abuse
Elder abuse often starts with small, seemingly normal transactions. Over time, these can lead to significant financial loss. Teller observation can be the first clue to prompt further investigation by the bank or local authorities.
Tellers are our first defense in stopping elder abuse!
BSA REQUIRES THAT ALL FINANCIAL INSTITUTIONS TO CREATE AND IMPLEMENT A PROGRAM TO IDENTIFY CUSTOMERS.
WHAT IS CUSTOMER IDENTIFICATION PROGRAM (CIP) OR (MIP).
Reasonable belief as to the member's true identity. We have notice to members in our lobbies and at the desk of anyone who is opening up accounts.
YOU CAN INFORM A CUSTOMER THAT A CTR IS GOING TO BE FILED? TRUE OR FALSE
WHAT IS TRUE
There is nothing wrong with sharing this information, with your customer. Make sure the customer's identification is updated, before the customer leaves the bank.
CAN YOU INFORM THE CUSTOMER THAT A SAR IS BEING FILED
WHAT IS NO
Very Confidential. You will not necessarily know if a SAR has been filed or not. Do not talk amongst co-workers but talk to your supervisor and your supervisor will inform the BSA Officer.
Any Subpoenas or Law Enforcement request must be reported to the BSA Officer.
THE DRIVERS LICENSE, DATE OF BIRTH, PHYSICAL ADDRESS, THEIR IDENTIFYING NUMBER (SSN,EIN,ITIN), AND THEIR LEGAL NAME IS PART OF WHAT?
WHAT ARE THE FOUR REQUIREMENTS WE MUST OBTAIN FOR A NEW CUSTOMER FOR CIP PROGRAM
The purpose is to assist in the detection and prevention of money laundering and terrorist financing.
A MONEY SERVICE BUSINESS (MSB)
(We DO NOT bank these businesses)
WHAT IS a business that:
is a currency dealer or exchanger
is a check casher
is an issuer, seller or redeemer of traveler's checks, money orders or store value cards
is a money transmitter
has activity greater than $1,000 per person per day
THE OFFICE OF FOREIGN ASSETS CONTROL ACRONYM
WHAT IS O.F.A.C.
Apply to all U.S. persons
Facilitating a transaction for a person or entity on the OFAC list will be in violation of OFAC laws. Potential matches must be cleared BEFORE the transaction is done. All new members need to be ran through OFAC before opening an account or purchasing a cashier's check. Conducting the OFAC 10 days later is a violation of the regulations.
IS IT POSSIBLE TO BE EXEMPT FROM CTR'S? Yes or NO
WHAT IS YES
Phase I =Domestic Banks, Government entities, Listed Businesses
Phase II = Non-listed businesses- account for 2 months, frequent reportable transactions (5 in 12 month), Incorporated or organized under U.S. laws, and is not an ineligible business type
A SUSPECTED SUSPICIOUS ACTIVITY MUST BE REPORTED WITHIN _____ DAYS OF ITS OCCURRENCE
WHAT IS 30 CALENDAR DAYS
After first reported to the BSA Officer, they have 30 calendar day to review and investigate prior to be submitted.
DIRECTLY OR INDIRECTLY OWNING 25% OR MORE OF THE BUSINESS.
WHAT IS A BUSINESS' BENEFICIAL OWNER?
New to beneficial owner information as of 2025 all businesses will have to register on FinCEN.
The Credit Union must have a program to continually check member records for update of information (name,address, photo ID, ect.)
WHAT IS MEMBER DUE DILIGENCE
This is done when you are updating member information on their account. It is also done back office by compliance when doing mini account audits.
ALL RECORDS RELATED TO MAINTAINING BSA COMPLIANCE WILL BE RETAINED FOR A PERIOD OF NO LESS THAN ________ YEARS.
WHAT IS FIVE
All information collected that falls under BSA will has a retention of 5 years. All CIP documents used to open an account is retained for 5 years after the date the account was closed.
THE BANK HAS THIS MANY CALENDAR DAYS AFTER THE "BUSINESS" DAY OF THE TRANSACTION TO FILE A CTR.
WHAT IS 15 calendar days
Filing must be within 15 calendar days of the transaction. Branches complete and send to Vickie, she then validates information to system reports prior to submission to FinCEN through Verafin.
Iota Branch scans the entire report along with supporting documents to save time. Is this branch interested in scanning their CTR's?
A CUSTOMER COMES IN THE BANK A FEW TIMES A WEEK AND MAKES A DEPOSIT JUST SHY OF $10,000 EVERY TIME AND WE ARE UNAWARE OF ANY APPARENT ECONOMIC, BUSINESS, OR LAWFUL PURPOSE, WHAT TYPE OF SUSPICIOUS ACTIVITY
WHAT IS KNOWN AS STRUCTURING
Activity just under the BSA/CTR requirement, trying to avoid reporting.
WHAT ARE ACCEPTABLE DOCUMENTS WHEN VERIFYING THE IDENTITY OF THE BUSINESS?
WHAT ARE ARTICLES OR INCORPORATION OR ORGANIZATION, STATE-ISSUED CERTIFICATION OF INC, CERTIFICATE OF ASSUMED NAME, BUSINESS LICENSE
WHY DOES THE BSA DEPARTMENT ASK SO MANY QUESTIONS ABOUT FINANCIAL TRANSACTIONS AND OUR CUSTOMERS
What is the BSA department ask detailed questions about transactions because the BSA is the primary U. S. anti money laundering (AML) and counter terrorist financing law. Its purpose is to detect and prevent criminals from using the US financial system to hide the source or destination of illicit funds.
So when we hear, the customer is private, or I don't know they didn't say, or I didn't ask, you are not doing your job as a frontline teller. You need to know your customer. That is part of your job!
Roll play!