BANK SECRECY ACT (BSA)

Our procedures are designed to assist the Bank in reviewing and improving its compliance with the requirements under the Bank Secrecy Act and Anti-Money Laundering rules. Our scope includes the following:

Evaluating corrective actions taken in response to prior reviews or regulatory examinations, if applicable;

Reviewing the Bank Secrecy Act, Customer identification Program (CIP), Office of Foreign Asset Control (OFAC) and anti-money laundering (AML) policies, procedures and program;

Evaluating knowledge and understanding of personnel;

Reviewing the scope, frequency, and documentation of training;

Reviewing large cash transactions and currency transaction reports (CTRs);

Evaluating compliance with record retention requirements;

Reviewing correspondence with the government;

Reviewing wire transfer activity, documentation, and departmental procedures;

Reviewing exemptions;

Reviewing 314(a) search request processes and procedures;

Reviewing suspicious activity reports (SARs);

Reviewing account reviews, including high-risk and MSB accounts;

Reviewing accounts held by foreign nationals, if any;

Reviewing processes related to the Bank’s AML/fraud detection software, as available;

Reviewing policies and processes related to beneficial ownership;

Reviewing policies and processes related to NSL (National Security Letters);

Evaluating guidelines for detecting, preventing, and reporting suspicious activities;

Evaluating CIP compliance and account opening procedures;

Evaluating implementation of US Patriot Act requirements;

Evaluating compliance with OFAC requirements;

Evaluating ACH processes and monitoring related for compliance with BSA and OFAC;

Evaluating BSA processes and monitoring as they relate to ACH services;

Evaluating the bank’s Anti-Money Laundering program risk assessment and procedures; and

Reviewing sales of monetary instruments.

All BSA audits will be performed by auditors carrying a professional certification for BSA auditing – Certified Anti-Money Laundering Specialist (CAMS) and / or Certified BSA/AML Professional (CBAP). At the conclusion of our work, we will issue a report that includes a rating to help management and the Board more clearly understand the bank’s compliance with BSA and other related laws and regulations.