for Financial Institutions
These checklists are designed to provide institutional compliance units responsible for Bank Secrecy Act and Anti-Money Laundering Program compliance with lists of requirements that should be satisfied and issues that should be considered by the institution in order to meet regulatory standards. There are separate checklists for banks, broker-dealers, and money services businesses.
The individuals or divisions of the institution responsible for BSA and AML compliance should make certain that all items on the checklist have been considered. Some issues may not apply to specific institutions because of size or operational structure, but no issue should be automatically ignored. Also, some issues may raise questions and bring to light problems that need further attention, and merely filling in an answer may not be a sufficient response.
Portions of the checklist should be used by more than one section of the institution. Thus, sections of the institution that interface with customers should consider the customer identification and transaction reporting requirements. Personnel departments should be familiar with training requirements. Management information systems should consider all issues that involve obtaining, saving, or extracting data, and should specifically be familiar with interdiction procedures for OFAC compliance.
Upper levels of management should be familiar with the general requirements contained in the checklist, but should be specifically familiar with the results of internal audits and external examinations. Upper management should also be familiar with agreements by which an institution delegates responsibility to another institution, or shares information with another institution.
All sections of the institution should be familiar with the red flags indicating that an activity may be suspicious and appropriate for reporting.
The checklist is part of the online service of Money Laundering, Terrorism and Financial Institutions and is designed to be used in conjunction with that service and the USA PATRIOT Act Monitor and email news releases that update the service. In addition, compliance personnel should monitor the relevant websites of FinCEN (www.fincen.gov), OFAC (www.treas.gov/offices/enforcement/ofac), and the appropriate institutional regulatory agencies for new requirements and interpretations of existing rules and requirements.
Compliance issues are often described as “risk based” and the approaches of a given institution may vary depending on the institution’s customer base, the services it provides, the location and size of its non-U.S. operations, and other factors. This checklist is a tool to aid in compliance, but does not assure compliance, and senior management and compliance personnel should be prepared to spend the necessary effort to assure that an institution is making the best possible effort to satisfy both the letter and spirit of the regulatory requirements.
Money Services Businesses
Red Flags for Suspicious Activities at Financial Institutions
Compliance Checklist for Casinos, Card Clubs and Indian Gaming Establishments
[USA Patriot Act Monitors] [Compliance Tools]
[Federal Register: 2004-2003 2002 2001 2000-1996]
[Money Laundering, Terrorism & Financial Institutions Online]
[Legislative Materials] [Agency Reports: GAO Treasury]