Can you summarize Core Examination Procedures for Regulatory Requirements and Related Topics > Beneficial Ownership Requirements for Legal Entity Customers (2018)?
This document outlines the regulatory requirements for banks to identify and verify the beneficial owner(s) of legal entity customers. The purpose of these requirements is to enhance transparency and prevent money laundering and other illicit activities. A legal entity customer is defined as a corporation, limited liability company, or other entity that is created by filing a public document. The beneficial owner(s) of a legal entity customer can be determined under both a control prong and an ownership prong.
Can you summarize Core Examination Procedures for Regulatory Requirements and Related Topics > Foreign Correspondent Account Recordkeeping, Reporting and Due Diligence?
This document outlines the regulatory requirements and due diligence procedures for banks and financial institutions that maintain correspondent accounts for foreign shell banks and engage in foreign correspondent banking activities. The document covers the provisions of the USA PATRIOT Act, which aim to protect the U.S. financial system from money laundering and terrorist financing. It requires banks to establish and maintain records for foreign banks, conduct due diligence on foreign correspondent accounts, and take steps to prevent indirect banking services to foreign shell banks.
Can you summarize Core Examination Procedures for Regulatory Requirements and Related Topics > Funds Transfers Recordkeeping?
This document governs the compliance of banks and financial institutions with statutory and regulatory requirements for funds transfers. It outlines the recordkeeping requirements for banks involved in funds transfers, including the collection and retention of specific information depending on the bank’s role in the transfer. The document also introduces the ‘Travel Rule’ which requires financial institutions to include certain information in transmittal orders for funds transfers. Intermediary institutions are required to retain records of payment orders, while beneficiary’s banks must retain records of payment orders and verify the identity of the recipient.
Can you summarize Core Examination Procedures for Regulatory Requirements and Related Topics > Information Sharing?
This document governs the information sharing procedures to deter money laundering and terrorist activity. It applies to financial institutions. The document outlines the requirements for sharing information between law enforcement agencies and financial institutions under Section 314(a) of the USA PATRIOT Act. It also covers voluntary information sharing under Section 314(b) of the USA PATRIOT Act. The document specifies the search requirements, use restrictions, confidentiality obligations, and documentation requirements for financial institutions.
Can you summarize Core Examination Procedures for Regulatory Requirements and Related Topics > Office of Foreign Assets Control?
This document pertains to the assessment of a bank’s risk-based Office of Foreign Assets Control (OFAC) compliance program. OFAC is an office of the U.S. Treasury that administers and enforces economic and trade sanctions. The document outlines the requirements for banks to comply with OFAC regulations, including blocking accounts and property of specified countries, entities, and individuals, prohibiting unlicensed trade and financial transactions, and reporting blocked and rejected transactions to OFAC.
Can you summarize Core Examination Procedures for Regulatory Requirements and Related Topics > Private Banking Due Diligence Program (Non-U.S. Persons)?
This document outlines the requirements for U.S. financial institutions to implement a due diligence program for private banking accounts established, administered, or maintained for non-U.S. persons. The program must include policies, procedures, and controls to detect and report money laundering and suspicious activity. Private banking accounts are defined as accounts that require a minimum aggregate deposit of funds or other assets of not less than $1,000,000 and are established on behalf of or for the benefit of one or more non-U.
Can you summarize Core Examination Procedures for Regulatory Requirements and Related Topics > Suspicious Activity Reporting?
This legal document governs the policies, procedures, and processes related to monitoring, detecting, and reporting suspicious activities in the banking industry. It applies to banks, bank holding companies, and their subsidiaries. The document emphasizes the importance of suspicious activity reporting in combating terrorism, terrorist financing, money laundering, and other financial crimes. It outlines the specific requirements for filing a Suspicious Activity Report (SAR) and the thresholds for reporting. The document also highlights the safe harbor provision that protects banks from civil liability for reporting suspicious transactions.
Can you summarize Developing Conclusions and Finalizing the Exam > Developing Conclusions and Finalizing the Exam (2020)?
This document provides guidance to examiners conducting BSA/AML examinations on banks. The objective is to formulate conclusions about the adequacy of the banks BSA/AML compliance program and its compliance with BSA regulatory requirements. Examiners should focus on whether the bank has established appropriate processes to manage ML/TF and other illicit financial activity risks, and whether the bank has complied with BSA requirements. Conclusions and findings should be presented in a written format for inclusion in the report of examination (ROE).
Can you summarize Expanded Examination Procedures for Consolidated and Other Types of BSA/AML Compliance Program Structures > BSA/AML Compliance Program Structures?
This document provides an overview of BSA/AML compliance program structures for banking organizations. It emphasizes the importance of having a comprehensive BSA/AML compliance program that addresses BSA requirements applicable to all operations of the organization. The document discusses different approaches to structuring and managing the program, including consolidation across entities within an organization or as part of an enterprise risk management framework. It highlights the need for a consolidated approach to reflect the organization’s business structure, size, and complexity, and to effectively address risks and legal requirements.
Can you summarize Expanded Examination Procedures for Consolidated and Other Types of BSA/AML Compliance Program Structures > Foreign Branches and Offices of U.S. Banks?
This document provides an overview of the assessment of U.S. banks’ systems to manage risks associated with their foreign branches and offices. It emphasizes the importance of effective monitoring and reporting systems. U.S. banks open foreign branches and offices to meet customer demands, expand their products or services, or facilitate growth. The document highlights that while specific BSA requirements are not applicable to foreign branches and offices, banks are expected to have policies, procedures, and processes in place to protect against money laundering and terrorist financing risks.