BSA Basics
This is the name of the BSA Officer.
Who is Kory Schneider?
Cash transactions involving more than this dollar amount will trigger the filing of a CTR.
What is $10,000?
True or False: You must notify the member when a SAR is being filed on them.
What is False? It is PROHIBITED to disclose to a member or any other unauthorized person that a SAR is being filed.
True or False: Customer Due Diligence (CDD) information required to open an account include Occupation or Nature of Business, US Citizen?, Source of funds, products and services provided and anticipated transaction activity (checking/savings).
What is True?
True or False: Chris G and Jackie T collect a bonus based on the number of file maintenance corrections they identify.
What is false? That is just silly, they prefer to send no corrections at all. :)
Name 2 of the 5 Pillars of BSA.
What are 2 of the following:
Internal Controls BSA Officer
Independent Testing Training
Customer Due Diligence
True or False: If a member deposits $8,000 at our Appleton branch and on the same day deposits $3,000 at our Kimberly branch, a CTR does not need to be filed since the deposits were run in two separate transactions and at two separate branch locations.
What is False? We must aggregate all deposits made in one day across all of our branches.
This Operations Department employee has the same initials as the Suspicious Activity Report (SAR).
Who is Stephanie Ann Roberts?
These are the 2 prongs of Beneficial Ownership.
What is Ownership prong and Control prong?
100 Bonus Points: Define each prong.
True or False: Violations of BSA requirements may hold civil and/or criminal penalties to the financial institution and/or involved employees.
What is true? The Financial Institution may face civil penalties for negligence, willful violation or practice of negligence. An employee may face criminal penalties if committing a willful violation.
The acronym FinCen stands for:
What is Financial Crimes Enforcement Network?
The bank has this many calendar days after the "business day" the reportable cash transaction occurred to file a CTR online.
What is 15?
True or False: If 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 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. Tax Identification Number?
This Operations Department employee has been with EWSB for 42 years and started right out of high school.
Who is Sara Romenesko?
Name 2 areas of BSA that aid law enforcement by uncovering criminal activities.
What are 2 of the following:
Money laundering
Drug trafficking
Tax fraud
Possible terrorist financing
True or False: A customer cashes a check for $15,000. Later that same day, they return 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? A CTR must be filed for both transactions.
This department of the bank monitors activity and works with the BSA officer to determine if a SAR should be filed.
This is what you should do when you are having a hard time determining if an OFAC 'hit' relates to the member you are completing a search on.
What is contact the BSA Officer or Operations Department?
True or False: A member deposits $4,000 in cash in their savings account and wants to withdraw $3,800 in a money order. This is not considered a Monetary Instrument purchased with cash since it was deposited into their account first.
Name the three steps that occur in Money Laundering.
What are Placement, Layering and Integration?
Placement is the first stage of money laundering, which involves transferring funds to a legitimate source through financial institutions, casinos, financial instruments, etc.
After the funds have entered the financial system, the Layering stage occurs, with the launderer moving the funds around to distance them from their source and disguise the money trail.
The Integration phase is the final stage of money laundering. Money is now legally returned to criminals after being introduced into the financial system, often broken down into multiple smaller financial transactions or purchases.
This is what you should do if a member changes their mind about completing a reportable transaction when you start gathering the information for a CTR.
What is continue to update member information that would be needed for the CTR and report it on an Incident report?
NOTE: Incident reports are monitored for potential SAR filing.
Criminal violations aggregating to this dollar amount must be reported on a SAR when the subject can be identified.
What is $5,000?
This is the most widely used acceptable ID requirement.
What is a government issued, non-expired photo ID?
This is the total number of kids the Operations Department staff has. (Sara, Chris, Steph, Jackie T)
What is 8?