From One Pillar to Another
This is the (unofficial) 5th Pillar of the BSA/AML Program
What is Customer Due Diligence?
This protects banks from civil liability for suspicious activity reporting.
What is safe harbor?
Situations where the compliance staff reports to the management of the business line could present this.
What is conflict of interest?
These include designated terrorists and narcotics traffickers.
What are SDNs?
These act as intermediaries or financial liaisons between their client and a bank.
What are Professional Service Providers?
This should incorporate current developments and changes to BSA regulatory requirements.
What is training?
Currency transactions need not be reported if they involve this group.
What is exempt persons?
This is the central point where BSA/AML risks throughout the organization are aggregated
What is the Risk Assessment?
This is one of the required elements of CIP to identify and verify both individual or legal entity customers.
What is a TIN?
Required to register with FinCEN, these present varying levels of money laundering risk based on their products, services, and core clientele.
What are Money Service Businesses?
Independent testing of specific BSA requirements should be this to evaluate the quality of risk management across the organization.
What is risk-based?
This landmark legislation amended the Bank Secrecy Act to require financial institutions to establish an AML Program.
What is the USA PATRIOT Act?
The audit function must remain this regardless of program structure.
What is independent?
This is a privately owned, multilateral payments system used for large dollar payments.
What is CHIPS?
These maintain correspondent accounts at U.S. banks to access the U.S. financial system, obtain products and services that may not be available in their jurisdiction.
What are foreign financial institutions?
It is important to know this is the cornerstone of a strong BSA/AML Program.
What is customer due diligence?
This rule requires financial institutions to include certain information in the transmittal order for any funds transfer of $3,000 or more. Passport not required.
What is the Travel Rule?
This is responsible for communicating and reinforcing the BSA/AML compliance culture established by the board.
What is senior management?
The first letter in the abbreviation IVTS denotes the central risk associated with the money movement of hawalas.
What is Informal?
These are used to hold individual funds and investments with ownership vested through bearer or registered shares.
What are Private Investment Companies (or PICs)?
To have this, a BSA Compliance Officer needs a clear line of communication to Board of Directors
What is independence?
A private banking account means an account (or any combination of accounts) maintained at a bank that requires a minimum aggregate of not less than this
What is $1 million
This has the primary responsibility for ensuring that the bank has a comprehensive and effective BSA/AML compliance program.
What is the board of directors?
This abbreviation is used to denote a special trust account used by lawyers to fund civil legal aid for low-income individuals.
What is an IOLTA?
Generally not subject to BSA/AML requirements, these provide payment processing services to merchants and other entities.
What are Third Party Payment Processors (or TPPPs)?