GENERAL ANTI-MONEY LAUNDERING PROGRAM REQUIREMENTS

• Functional Regulator or Self-Regulatory Organization
• Performing BSA/AML Responsibilities for Mutual Funds
• Providing Services for Hedge Funds
• Providing Services for Closed-End Funds
• Introducing Broker Status
• Clearing Functions

INTERNAL COMPLIANCE

• Management Responsibilities
• Independent Testing of Internal Compliance

REPORTING RESPONSIBILITIES

• BSA Direct E-Filing System
• Currency Transaction Reporting
• Suspicious Activity Reporting
• Give-Up Arrangements and Joint Filings
• Managed Separate Account of an Insurance Company
• Reports of Transportation of Currency or Monetary Instruments
• Reports of Foreign Financial Accounts
• Reports of Transactions with Foreign Financial Agencies
• IRS Reporting

RECORDKEEPING RESPONSIBILITIES

• Funds Transfer Recordkeeping
• Funds Transmittal Recordkeeping

CUSTOMER IDENTIFICATION PROGRAM

• Identification
• Identity Verification
• Lack of Verification
• Customer Notice
• Reliance on Another Financial Institution
• Know Your Customer Program

OFAC COMPLIANCE

BSA TRAINING PROGRAM

SPECIFIC ACCOUNTS AND TRANSACTIONS

• Correspondent Accounts
• Correspondent Accounts for Foreign Shell banks
• Private Banking
• Concentration Accounts
• Overseas Branches and Offices

INFORMATION SHARING WITH GOVERNMENT AGENCIES

NATIONAL SECURITY LETTERS

DEFENSE DEPARTMENT AUTHORITY TO OBTAIN INFORMATION

INFORMATION SHARING WITH OTHER FINANCIAL INSTITUTIONS

PREPARING FOR EXAMINERS

Regulations covering brokers and dealers under the Bank Secrecy Act and other legislation have been developing rapidly, and at over 70 pages, this checklist is nearly as long as the checklist for banks. Staff devoted to compliance efforts should be highly trained and should frequently review the requirements for all sections of the institution.