• AML/CFT Health Check - United States Template

    The AML/CFT Health Check Tool contains a template specifically for the 6,500 United States Financial Institutions who are obligated to comply with the Bank Secrecy Act (BSA) /Anti-Money Laundering (AML) Regulations, which is based on the latest Federal Financial Institutions Examination Council (FFIEC), BSA/AML Examination Manual, which was jointly developed by U.S. Federal and State banking agencies (including FDIC and NCUA), the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC), to provide comprehensive guidance to reporting entities when conducting BSA/AML and OFAC reviews.

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AML/CFT Health Check – United States Template

The AML/CFT Health Check Tool contains a template specifically for the 6,500 United States Financial Institutions who are obligated to comply with the Bank Secrecy Act (BSA) /Anti-Money Laundering (AML) Regulations, which is based on the latest Federal Financial Institutions Examination Council (FFIEC), BSA/AML Examination Manual, which was jointly developed by U.S. Federal and State banking agencies (including FDIC and NCUA), the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC), to provide comprehensive guidance to reporting entities when conducting BSA/AML and OFAC reviews.

This pre-defined template contains over contains over 600 out-of-the-box examination procedures, with the ability to assess against either Core examination procedures, Expanded examination procedures, or both.

Core Examination Procedures

Assessing the BSA/AML Compliance Program

  • Scoping and Planning
  • BSA/AML Risk Assessment – General, Risk factors (Product/service, customers and entity and geographic locations)
  • BSA/AML Compliance Program
    • General
    • Risk Assessment link to the BSA/AML Compliance Program
    • Internal Controls
    • Independent Testing
    • BSA Compliance Officer
    • Training
    • Transaction Testing / Independent Testing
  • Developing conclusions and finalizing the examination
    • Formulating conclusions
    • Determining the underlying cause
    • Discuss findings with the Examiner-in-charge and identify necessary action
    • Preparing the BSA/AML comments for the report of examination

Regulatory requirements and related topics

  • Customer Identification Program (and transaction testing)
  • Customer Due Diligence (and transaction testing)
  • Suspicious Activity Reporting
    • Identification of unusual activity
    • Transaction monitoring (manual)
    • Surveillance monitoring (automated)
    • Managing alerts
    • SAR decision making
    • SAR completion and filing
    • SAR transaction testing
  • Currency Transaction Reporting (and transaction testing)
  • Currency Transaction Reporting Exemptions (and transaction testing)
  • Information sharing (and transaction testing)
    • Between law enforcement and financial institutions
    • Voluntary information sharing
  • Record-keeping
    • Purchase and sale of monetary instruments (and transaction testing)
    • Funds transfers (and transaction testing)
    • Foreign correspondent account record-keeping, reporting and due diligence (and transaction testing)
      • General requirements
      • Foreign shell bank prohibition and foreign correspondent account record-keeping
      • Special due diligence program for foreign correspondent accounts
  • Private Banking Due Diligence (and transaction testing)
  • Special measures (and transaction testing)
  • Foreign bank and financial accounts reporting (and transaction testing)
  • International transportation of currency or monetary instruments reporting (and transaction testing)
  • Office of Foreign Assets Control (and transaction testing)

Expanded Examination Procedures

For consolidated and Other Types of BSA/AML Compliance Program Structure

  • BSA/AML Compliance Program Structures
  • Foreign Branches and Offices of U.S. Financial Institutions (and transaction testing)
  • Parallel Banking (and transaction testing)

Products and Services

  • Correspondent Banking Accounts (Domestic) (and transaction testing)
  • Correspondent Banking Accounts (Foreign) (and transaction testing)
  • Bulk Shipment of Currency (and transaction testing)
  • U.S. Dollar Drafts (and transaction testing)
  • Payable Through Accounts (and transaction testing)
  • Pouch Activities (and transaction testing)
  • Electronic Banking (and transaction testing)
  • Funds Transfers (and transaction testing)
  • Automated Clearing House Transactions (and transaction testing)
  • Prepaid Access (and transaction testing)
  • Third-Party Payment Processors (and transaction testing)
  • Purchase and Sale of Monetary Instruments (and transaction testing)
  • Brokered Deposits (and transaction testing)
  • Privately Owned Automated Teller Machines (and transaction testing)
  • Nondeposit Investment Products (and transaction testing)
  • Insurance (and transaction testing)
  • Concentration Accounts (and transaction testing)
  • Lending Activities (and transaction testing)
  • Trade Finance Activities (and transaction testing)
  • Private Banking (and transaction testing)
  • Trust and Asset Management Services (and transaction testing)

Persons and Entities

  • Nonresident aliens and foreign individuals (and transaction testing)
  • Politically Exposed Persons (PEPs) (and transaction testing)
  • Embassy, Foreign Consulate and Foreign Mission Accounts (and transaction testing)
  • Nonbank Financial Institutions (and transaction testing)
  • Money Services Businesses (and transaction testing)
  • Professional service providers (and transaction testing)
  • Non-Governmental Organizations and Charities (and transaction testing)
  • Business Entities (Domestic or Foreign) (and transaction testing)
  • Cash Intensive Businesses (and transaction testing)

Based on guidance developed by

 
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