What are the five pillars of an effective BSA/AML 1. Designation of a BSA compliance officer by the Board.
compliance program? 2. Provide for a system of internal controls to ensure ongoing compliance
3. Provide for independent testing to be conducted by credit union personnel or
outside parties
4. Provide training for appropriate personnel
5. Appropriate risk-based procedures for conducting ongoing member due
diligence
Who all is required to receive BSA/AML training? New staff, BSA Compliance Officer, Board of Directors, and all appropriate
personnel
True/False: BSA/AML training should be tailored to the True
person's specific responsibilities
How often does BSA training need to be conducted? Every 12 to 18 months
What records of the BSA training program do credit Records of training and testing materials, the dates of training sessions and
unions need to keep? attendance records.
True/False: The credit union's board of directors is True
ultimately responsible for the credit union's BSA
compliance?
, The BSA Officer must be knowledgeable of: f. all of the above
a. BSA, and related regulations
b. The credit union's products and services
c. The credit union's members
d. The credit union's neighborhoods
e. a&b
f. All of the above
True/False: If you are a small credit union it is acceptable False
to have the BSA officer determine when a CTR is
necessary, fil out the CTRs, and determine who is eligible
for a CTR exemption.
Regulators recommend that independent test of your b. Every 12 to 18 months
BSA program should be done:
a. Annually
b. Every 12 to 18 months
c. Whenever necessary
d. Before each exam
Which of the following products and services could d. All of the above
possibly pose a higher risk for illegal activities?
a. Wire transfers
b. Monetary instruments
c. Traveler's checks
d. All of the above
Section 326 of the USA Patriot Act requires financial 1. implement reasonable procedures to verify the identity of any person seeking
institutions to: to open an account
2. maintain records of the information used to verify the person's identity
3. determine whether the person appears on any lists of known or suspected
terrorists or terrorist organizations provided to the FI by any government agency
4. provide the member opening a new account with notice of the information
collection requirement.
A financial institution's CIP should be tailored to: 1. it's size
2. location
3. types of accounts offered
4. methods of opening accounts; and
5. any other risk factors the FI believes affects its CIP procedures
What four pieces of information are credit union's 1. name
required to collect on each new member? 2. address
3. date of birth
4. identification number
What are the two methods a credit union can use to verify 1. documentary
identity? 2. non-documentary