Required Documents
Acceptable verification for partial NGO BOS exclusion (name any 2)
IRS 990, Determination Letter, Articles of Organization noting 501c3, Business license showing non-profit, or other client provided documentation as outlined in the DD Procedures
Lexis Nexis Negative News search parameter for a client named John Jacob Jingleheimer Schmidt
John Schmidt
ALL transactions with this jurisdiction type are required to be discussed in our narrative
OFAC
BOS for Jack and Jill Inc., an ice cream stand, states no owners over 25%. Why should this set off your spidey-senses?
A single ice cream stand is likely to have fewer than 4 owners, and almost certainly less than 10, meaning we would expect one or more owners to be listed in almost all instances.
Point value of a Manual Risk Adjustment for PayFAC/ISO or complex PIC/PIV
1.0
Documentation needed for an NCUA credit union with only a CDA.
DCB Questionnaire with FCG Approval
Banking License
Correspondent Banking Agreement, if applicable and available
WorldCheck search type for Mickey Mouse Clubhouse Inc.
Organization
Current High-Risk Review scope if:
Prior High-Risk scope 10/10/2022-10/10/2023
AML Investigations
11/12/2023-2/14/2024
7/31/2024-10/1/2024
Depends!
If the final case was a SAR: we've got a quick close
If the final case was a No-SAR:
Section I - 10/11/2023 - current
Section V - 10/2/2024 - current
ATM
MSB
Actual Activity
Marijuana
Avoid a material return by including this type of alert with your review case
PRE
Risk factor that requires a Title 31 program
(High-Risk) Casino
Type of name identified by Lexis SmartLinx which requires all searches
Actual Name - where bank records may be incorrect, such as spelling errors
A writeup of this activity, deemed to be unreasonable, might sound like...
Credits: 75% funded by P2P activity, 25% funded by cash
Debits: 50% P2P activity, 30% retail shopping/restaurants/etc., 20% travel expenses
Structuring, unknown source of funds, rapid movement, transactions with unknown purpose, potential human trafficking, client age or employment, etc.
Moderate NGO shouldn't have HRC/VHRC/OFAC exposure, or they'd be High/Ultra High. When we see these during a client review, we may need to question if their RSQ and scoring is correct. (Name 2)
Service Type: Foreign Item
Account Type: FXG
Activity: Actual ACH/Wires
Research: Website identifying foreign jurisdictions, services, BOD, etc.
Teammates most likely able to assist you with soft-stop related questions/documents - name any 2
Avoid a material return by including this Excel document for cases with risk-factor documents
Risk Factor Required Documentation SUMMARY
States which assumed/fictitious/trade names are searchable at the state level (name any 3)
Alaska, Colorado, Florida, Idaho, Illinois*, Indiana*, Maine*, Michigan, New Hampshire, New York*, Ohio, Oregon, Pennsylvania, Utah, Vermont, Washington
* = depends on entity type
To mitigate the following activity might sound like ...
Credits: 50% payroll, 25% P2P, 20% cash, 5% internal transfers
Debits: 40% ACH, 40% debit card activity, 10% P2P, 10% internal transfers
Overall dollar amounts, no pattern of structuring, clear payment of living expenses, known relation of counterparties, client age or employment, etc.
Type of risk(s) this entity might be scored for, if they were our client.
PSP
Debt Collection
TPPP
Actual Activity/HRG
Details needing to be discussed in Actimize DD Case Notes Resolution (any 3)
Reason for scoring, any OFAC details, any concerns (no contact, 356, missing docs), whether a review was completed or why not, client interview notes, filepath, multiple IPIs (page 122 DD procedures)
Pillars of an AML P&P Document for MSB clients (name any 3)
Client details and effective/issue date (Who does the document belong to)
Compliance Officer Duties (may or may not name the officer directly)
Filing Requirements (CTR & SAR)
Employee Training
Independent Audit (frequency and/or who/how it will be done)
No "blanks" - all fields requiring a response/initials/signature/date are complete
If Thrivur Health LLC were our client and used the "Publicly Traded" full exclusion, what issue(s), if any, would we have?
Incorrect exclusion - majority owned by publicly traded company CoreCivic
Engage FCG as CoreCivic being a private prison (prohibited industry)
What concerns, if any, might we have if this were our client and activity was observed with Austria, Bulgaria, Costa Rica, and Dominican Republic?
Export Control / FinCEN BIS
If this were our client, would we expect them to be scored for wholesale jeweler - why or why not?
Yes - materials used, prices x sales, reference to Turkish vendor.
We do this, if two different controlling parties are identified for related entities within an organization structure.
List and review both individuals accordingly. Outreach is not required to verify which might be correct* as the definition of a controlling party may apply to multiple people.
*assuming no other evidence draws this into question, such as internet research saying one has left the company.