Would anyone be willing to share a negotiable instruments audit program with me? I have tried to find a FDIC or an OCC examination guide but I have been unable to find one.

Thanks

What is your objective? BSA compliance?

Some thoughts:

-ensure required recordkeeping information is recorded/retained for cash purchases of $3,000 to $10,000 (make sure if bank policy is to deposit cash first and then withdrawal to make a purchase that these are still treated as cash sales for BSA recordkeeping purposes)

-if your bank policy is not to sell to non-customers, ensure adherence to the policy

-ensure controls are followed regarding receipt and/or destruction of negotaible instruments(will depend on bank procedures as well as the vendor's procedures/requirements - for example, if you sell amex gift checks they may have procedures for receiving deliveries [dual control, verify count] and destruction)

-ensure proper controls are in place regarding negotiable instrument inventory (dual control, periodic inventory, logs, etc. - some of this will depend on your bank's procedures)

-if bank policy is to perform an OFAC scan on purchaser or payees, ensure procedures are being followed.

I hope this helps.