The Bank Secrecy Act/anti-Money Laundering

Front 1

The Bank Secrecy Act/Anti-Money Laundering Acronym or Nickname is?

Back 1

BSA/AML

Front 2

The Bank Secrecy Act/Anti-Money Laundering (BSA/AML) was created in?

Back 2

1970

Front 3

The Bank Secrecy Act/Anti-Money Laundering (BSA/AML) of1970 Main Purpose is?

Back 3

To prevent money laundering.

Front 4

The Bank Secrecy Act/Anti-Money Laundering (BSA/AML) of1970 Entity Responsible for Enforcement is ?

Back 4

FinCEN or Financial Crimes Enforcement Network

Front 5

Per the Bank Secrecy Act/Anti-Money Laundering or BSA/AML financial institutions must institute a ?

Back 5

A compliance program to detect money laundering and suspicious activity.

Front 6

BSA/AML: There are four pieces to this compliance program used to detect money laundering and suspicious activity and they are?

Back 6

1. Risk Assessment;

2. A system of internal controls to ensure ongoing compliance;

3. Independent testing of BSA/AML compliance;

4. The designation of an individual or individuals responsible for managing BSA compliance; and

5. Training for appropriate personnel.

Front 7

What is money laundering?

Back 7

Money laundering is a term used to describe a scheme in which criminals try to disguise the identity, original ownership, and destination of money that they have obtained through criminal conduct. The laundering is done with the intention of making it seem that the proceeds have come from a legiti-mate source.

Front 8

In addition to the internal review and creation of controls to detect money laundering, there must be an ______ testing by a third party every 12-18 months to determine that AML compliance is in place and that those internal controls are doing what they should be doing.

Back 8

Independent.

Front 9

Once their business risks are identified, they need to create?

Back 9

Internal controls and review all existing policies and procedures to make sure that they can achieve AML compliance.

Front 10

The last leg of the compliance plan is annual compliance training. This training is required for personnel that deal with situations where risk of money laundering exits this includes?

Back 10

MLOs.

Front 11

Suspicious Activity Reports or aka?

Back 11

SARs.

Front 12

Suspicious Activity Reports or SARs: These reports must be filed with FinCEN when one of the 4 following circumstances occurs:

Back 12

1. Insider abuse involving any amount. Whenever the bank detects any known or suspected federal criminal violation, or pattern of criminal violations, committed or attempted against the bank or involving a transaction or transactions conducted through the bank, where the bank believes it was either an actual or potential victim of a criminal violation or series of criminal violations, or that the bank was used to facilitate a criminal transaction, and the bank has a substantial basis for identifying one of the bank’s agents, or other institution-affiliated parties as having committed or aided in the commission of the criminal violation, regardless of the amount involved in the violation

Front 13

Suspicious Activity Reports or SARs: These reports must be filed with FinCEN when one of the 4 following circumstances occurs:

Back 13

2. Transactions aggregating $5,000 or more where a suspect can be identified.Whenever the bank detects any known or suspected federal criminal violation, or pattern of criminal violations, aggre-gating $5,000 or more, where the bank believes itwas the victim of a criminal violation, or that the bank was used to facilitate a criminal transaction, and the bank has a substantial basis for identifying a possible suspect or group of suspects.

Front 14

Suspicious Activity Reports or SARs: These reports must be filed with FinCEN when one of the 4 following circumstances occurs:

Back 14

3. Transactions aggregating $25,000 or more regardless of potential suspects.Whenever the bank detects any known or suspected federal criminal violation involving transactions conducted through the bank, involving or aggregating $25,000 or more in funds or other assets, where the bank believes it was either an actual or potential victim of a criminal violation, or that the bank was used to facilitate a criminal transaction, even though the bank has no substantial basis for identifying a possible suspect or group of suspects; or

Front 15

Suspicious Activity Reports or SARs: These reports must be filed with FinCEN when one of the 4 following circumstances occurs:

Back 15

4. Transactions aggregating $5,000 or more that involve potential money laundering or violations of the Bank Secrecy Act.Any transaction (which for purposes of this paragraph (a)(4) means a deposit, withdrawal, transfer between accounts, exchange of currency, loan, extension of credit, pur-chase or sale of any stock, bond, certificate of deposit, or other monetary instrument or investment security, or any other payment, transfer, or delivery by, though, or to a financial institution, by what-ever means effected) conducted or attempted by, at or through the bank and involving or aggregating $5,000 or more in funds or other assets, if the bank knows, suspects, or has reason to suspect that

Ο The transaction involves funds derived from illegal activities or is intended or conducted to hide or disguise funds or assets derived from illegal activities (including, without limitation, the ownership, nature, source, location, or control of such funds or assets) as part of a plan to violate or evade any federal law or regulation or to avoid any transaction reporting requirement under federal law

Ο The transaction is designed to evade any regulations promulgated under the Bank Secrecy Act; or

Ο The transaction has no business or apparent lawful purpose or is not the sort of transaction in which the customer would normally be expected to engage, and the bank knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction.

Front 16

The required SAR must be filed no later than?

Back 16

30 calendar days after the date of the initial detection of the issue.

Front 17

A bank must maintain a copy of any SAR filed and all supporting documentation for?

Back 17

5 years from the date of the filing.