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Tools you can use for your BSA, OFAC, PATRIOT Act, anti-terrorism, and customer identification needs.

TOOLS

This page has user contributed tools in order by category and title of the tool;
  • AML/BSA
    • Anti-Money Laundering Policy - Sample
    • BSA Exam Procedures 07-06
    • BSA Exemption Review Form
    • BSA "Flash" Training
    • BSA Jeopardy Training Game
    • BSA Risk Assessment Tool Set
    • BSA Skits
    • BSA/AML/OFAC Board Training
    • BSA/CIP Awareness Signs
    • Checklist for Evaluating KYC Software
    • High Risk Entities Worksheets
    • MSB Review and Risk Analysis Worksheet
    • Risk Matrix by Product Line or Area
    • SKIPO Training Game
    • 314(a) "What to Search" Cheat Sheet
    • 314(a) Records Requests
    • 314(a) Documentation Spreadsheet
  • CIP
    • Account Opening Worksheet
    • CIP Alien Identification Procedures
    • CIP Authorization Report Form for Pulling Consumer Report
    • Checklists for CIP
    • CIP ID Workflow Charts
    • CIP Lobby Notice, CIP Samples
    • CIP Policy
    • CIP Questionnaire for Departments
    • Guide for Developing a List of Acceptable Documentation-Individuals
    • Who The Customer is for CIP Purposes
  • OFAC
    • OFAC- Potential Hit Analysis Spreadsheet Sample
    • OFAC Procedures
  • SAR
    • Suspicious Activity Investigative Report Form
    • Suspicious Transaction Form



AML/BSA

Anti-Money Laundering Policy Sample
Wayne Barnett, CPA, of Wayne Barnett Software, has provided this sample AML policy: BSA Exam Procedures & High Risk Jurisdictions BSA Exemption Review Form
Background on the BSA Exemption Review Form
BSA "Flash" Training
The Edcomm Group provided a five question quiz to test your knowledge of when to use a SAR, MIL and CTR. This is a flash based game for the user to play within their web browser. BSA Jeopardy Training Game
BOL User Jennifer Foote, First National Bank in Manitowoc, WI had an idea. She wanted to create a BSA Jeopardy game to use in training. But she wasn't sure how to do it. Andy Z suggested linking worksheets in Excel and offered to put it together with her help on the questions and answers. Oops, sorry, this is Jeopardy, the answers and the questions. Jennifer used it soon after it was done and said it was very successful. Now it is being shared with you.

There isn't a PDF version because of the way the links were set up and the way it is written so as to appear on screen better. It is password protected, but the password is blank, there isn't one. You'll need to remember this so you can customize it.

  • BSA Jeopardy (.xls, an Excel file, right click to save the file to your PC.)
BSA Risk Assessment Tool Set
From Brenda Cantebury, BOL Advisory Roundtable member, we have five documents to assist in risk rating accounts. Related to these is the OCC's BSA Risk Summary Form. BSA Skits
LaReta Lowther has contributed four case studies/skits to be used in connection with Bank Secrecy Act Training. All four are included in one document. BSA/AML/OFAC Board Training
--Devil Queen and Empress EGB combined their resources and created two versions of PowerPoint programs that you can use to train your board of directors for the Bank Secrecy Act/Anti-Money Laundering and OFAC. This is meant to be higher level material than is commonly used for BSA staff training and is in two versions so you can choose between more or less detail. The second version has one additional slide, 26 in total. But the contents of the slides are different, so you have a choice. There are even speaker's notes to assist you along the way.

BSA/CIP Awareness Signs
--From the BOL staff, three signs to post to increase awareness of the importance of BSA and CIP compliance.
Checklist for Evaluating KYC Software
by World Compliance

High Risk Entities Worksheets
MSB Review and Risk Analysis Worksheet
Risk Analysis Checklist for BSA and AML
- Excel format

Risk Matrix by Product Line or Area
- from Sandy Spring Bank
SKIPO Training Game
BOL Users Leslie Callaway and Melissa Langley (Sandy Spring Bank) have shared a game they created -- SKIPO Jeopardy -- to train their employees on Suspicious Activity, Know Your Customer, Information Security, Privacy/Identity Theft, and OFAC. Try it -- and let them know what you think! (There are two sets below -- choose from PDF or Word .doc)

PDF Version Word .doc Version YOU MUST RIGHT CLICK ON EACH LINK AND "Save Target as" or "Save Link as", then open in Word. 314(a) "What to Search" Cheat Sheet
Make sure you're searching through everything you need to be searching through. Use Mary Beth Guard's cheat sheet for what to search under 314(a).

Section 314(a) Records Requests
To help you respond in a compliant manner to Section 314(a) search requests your institution receives from FinCEN, we've created a list of Do's and Don'ts.

314(a) Documentation Spreadsheet
BOL user Peg Eekhoff has created a spreadsheet to be used in connection with processing Section 314(a) search requests from FinCEN. It outlines each of the seven areas a financial institution must search, and makes it easy to document that the search was performed.

CIP
Account Opening Worksheet
-- Another BOL user contributed a worksheet developed by his operations area to be used for accounts opened in circumstances where the applicant is not present in person or all signers are not present. Alien Identification Procedures
BOL User Leslie Callaway has contributed information that relates to identification of alien customers and risk assessment data relating to lending to aliens, from diplomats to NRAs.
Authorization Report Form for Pulling Consumer Report on Authorized Signers on Business Accounts
Know who you're dealing with on business accounts. Obtain authorization to pull a credit report on the authorized signers.
Consumer Report Authorization for Authorized Signers on Business Accounts Checklists for CIP
by Ken Golliher and Mary Beth Guard CIP - ID Workflow Charts
-- John Irving with The Banker's Benchmark Company has contributed two identification workflow charts -- one for individual account holders and one for business account holders. They provide a visual reminder of the steps to be taken during the account opening process. >Lobby Notice, CIP Samples
Tina Sweet-Williams and Karen Stephenson have each furnished a sample of a lobby notice to inform customers about the customer identification requirements. Customer Identification Program Policy (samples)
-- Two BOL Users, Elena Little and Tina Sweet-Williams, have contributed samples of their own customer identification program policies. Get ideas for how to write or tweak your own!

Tina A. Sweet-Williams' policy -- revised 10/26/02: Elena Little's Policy: Looking for comprehensive bank policies on an extensive list of subjects? Click on over to the BOL Banker Store for a complete selection!

CIP Questionnaire for Departments
- from Sandy Spring Bank Guide for Developing a List of Acceptable Documentation -Individuals
by Ken Golliher Who The Customer is for CIP Purposes
- This tool originated in a discussion on Bankers' Threads and is intended to serve as a starting point, rather than a comprehensive guide, to determining who is the customer for CIP purposes. OFAC- Potential Hit Analysis Spreadsheet Sample
Because her bank has experienced a large number of false positives with the OFAC list, BOL Advisory Roundtable member Bonnie Mizrahi developed a spreadsheet for use in analyzing and documenting potential hits. In it, she details why a particular customer is not a true match for the name on the OFAC list. By using this as a sample, you can develop a similar tool for your own institution. OFAC Procedures
BOL User Pam Johnston developed these OFAC procedures.

SAR
Suspicious Activity Investigative Report Form
In response to an examiner's recommendation, Allan Virr, BOL Advisory Roundtable member, developed this form for all investigations, regardless of whether or nor a SAR is filed.

Suspicious Transaction Form
BOL User Michelle Nuckols, with Pierce Compliance Consultants, Inc. in Rockville, VA, created a tool originlly designed for BSA training. It is intended to help tellers, CSRs, loan officers, operations employees, and others compile their thoughts and pass along adequate information so that a SAR may be filed accurately, and in a timely manner.
As it evolved, the document helps that person filing the SAR, determine if there is sufficient cause. The document is then retained and helps support the decision and potentially influence similar decisions in the future.

Disaster Recovery Resources
Disaster Recovery Guidelines
Disaster Recovery and Business Resumption Planning
FFIEC Policy Statement on Contingency Planning



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