BSA
B.S.A. stands for this.
WHAT IS BANK SECRECY ACT
The Bank Secrecy Act was enacted in 1970 by congress as a way to detect and prevent money laundering.
C.T.R. Stands for this.
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"
S.A.R. STANDS FOR THIS.
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
A.M.L. stands for this.
What is Anti-Money Laundering
A set of procedures, laws and regulations designed to stop and practice of generating income through illegal actions.
Every employee and volunteer of a financial institution is required to do this at least annually as a part of this pillar.
What is BSA Training as a part of the third pillar.
(Pillar three) Training for appropriate personnel including the Board of Directors, The Supervisory Committee, Senior Management, and all other staff.
THE PROCESS OF PLACING, LAYERING, AND INTEGRATION OF FUNDS IS CALLED THIS.
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 THIS AMOUNT.
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.
The broader range of actions where an INSIDER takes action or fails to take action; where the credit union is harmed, takes on additional risk, or loses; and where the INSIDER or a related party somehow benefits
What is INSIDER abuse?
Example: A teller helps orchestrate the robbery of a bank or member who has made a large withdrawal.
An employee/volunteer fails to report known illicit activity.
MONETARY INSTRUMENT REPORTS ARE REQUIRED ON SALES OF MONETARY INSTRUMENTS SOLD FOR CASH IN AMOUNTS FROM ______ TO ________
WHAT IS $3,000 to $10,000
Monetary instruments = cashier's check's, money orders. Must record when a purchased with cash between $3,000 and $10,000. This log is kept by compliance.
This Pillar requires the credit union to have someone with adequate experience and knowledge to manage the BSA program. This person is typically the contact for auditors and examiners.
What is the Second Pillar of BSA?
Designation of a BSA Compliance Officer.
Alaina Varner is currently the designated BSA Compliance Officer.
THE PART OF BSA THAT REQUIRES THAT ALL FINANCIAL INSTITUTIONS CREATE AND IMPLEMENT A PROGRAM TO IDENTIFY MEMBERS/ 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 MEMBER THAT A CTR IS GOING TO BE FILED. TRUE OR FALSE
WHAT IS TRUE
There is nothing wrong with sharing this information, and sometimes it is necessary to disclose the CTR filing in order to gather the needed documents/ID Information.
Doing this could result in civil and criminal penalties. Violations may be enforced through civil penalties of up to $100,000 for each violation and criminal penalties of up to $250,000 and/or imprisonment not to exceed five years.
What is disclosing a SAR filing (Tipping of SAR filing)?
SAR filing is strictly confidential. Do not alert members to possible filing. You should not talk amongst co-workers regarding a SAR filing but talking to supervisors and Compliance is acceptable.
The four pieces of identifying information that we must obtain for a new member under CIP.
WHAT IS THE DATE OF BIRTH, PHYSICAL ADDRESS, THEIR IDENTIFYING NUMBER (SSN,EIN,ITIN), AND THEIR LEGAL NAME
(At Call Federal, we require an unexpired, DMV issued ID.)
For this pillar, Call Federal uses an outside vendor to provide an annual assessment of our BSA program- specifically looking for areas of vulnerability.
What is the Fourth Pillar?
Independent testing of BSA/AML Compliance
Done by PB Mares
OFAC STAND FOR THIS.
WHAT IS THE OFFICE OF FOREIGN ASSETS CONTROL
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.
Financial institutions are required to gather these pieces of personal identification information when filing a CTR.
What are:
Name; Physical Address; Social Security Number; Date of Birth; ID
A SUSPECTED SUSPICIOUS ACTIVITY MUST BE REPORTED WITHIN _____ DAYS OF ITS OCCURRENCE
WHAT IS 30 CALENDAR DAYS
After first reported to Compliance, they have 30 calendar day to review and investigate prior to submitting a SAR.
Violations of BSA can cause civil money penalties and possible criminal actions against this entity and/or people.
Who is Call Federal Credit Union and it's employees volunteers and directors.
According to the fifth pillar of BSA, the credit union must have a risk based procedures for conducting this.
What is Customer/Member Due Diligence?
We currently use a New Member questionnaire to gather information to develop a risk profile for all new members.
We monitor established accounts for red flags and we should always be sure to update members' addresses, phone numbers and ID information as often as is necessary.
ALL RECORDS RELATED TO MAINTAING BSA COMPLIANCE WILL BE RETAINED FOR A PERIOD OF NO LESS THAN ________ YEARS.
WHAT IS FIVE
All information collected that falls under BSA has a mandatory retention requirement of 5 years. All CIP (MIP) documents used to open an account is retained for 5 years after the date the account was closed.
THE CREDIT UNION 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. Once retail staff completes the CTR it goes to compliance to validate. Compliance then submits the CTR electronically to FinCEN.
The action of purposefully conducting cash withdrawals or cash deposits in such a way that avoids CTR filing requirements.
What is Structuring?
Cash activity just under the BSA/CTR filing thresholds, trying to avoid reporting.
Avoiding record keeping and reporting requirements, cash transactions below the CTR reporting requirements, refusal or reluctance to provide original identifying documents or other required information are all examples of this.
What are Red Flags?
This pillar ensures that the credit union has a written, risk-based policy that is reviewed and approved by the board of directors annually. It also defines the roles of each part of the credit union as it pertains to BSA and outlines procedures to keep the credit union in compliance.
What is the First Pillar of BSA?
Internal controls that ensure ongoing compliance.
This policy is based on the credit union's overall risk profile determined by factors such as the location of credit union branches, proximity of members' addresses to HIDTAs or HIFCAs and the types of products and services the credit union offers.