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#2199105 - 11/27/18 02:48 PM Non deposit/investments department and BSA
Megaman Offline
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Joined: Jul 2017
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The Bank I work for has a non-deposit/investment department. We are looking for a checklist list or what needs to be completed from a BSA Standpoint. The non-deposit/investment department is a duel employee (paid by the Bank) We are looking for some suggestions on what the BSA Department should be looking at for a review of this department. We have looked at the FFIEC guidance but looking to see what other Banks are doing. If anyone is willing to share what they are using for reviewing this department that would be greatly appreciated.

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#2199132 - 11/27/18 04:40 PM Re: Non deposit/investments department and BSA Megaman
ACBbank Offline
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If I understand your post correctly, I'm not sure a checklist will suffice. If you're offering a full suite of NDIPs you need to consider transaction monitoring, OFAC screening, DD on the customers, etc. Is this Department regulated by FINRA?
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#2199473 - 11/30/18 02:20 PM Re: Non deposit/investments department and BSA Megaman
Big Dog Offline
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Based on your use of "dual employee" it sounds like your NDIP products are through a networking arrangement with a broker-dealer. In this situation, the customers are actually customers of the broker-dealer as far as the NDIP products are concerned. From a BSA standpoint, the BSA Officer should perform an annual review of the broker-dealers BSA program (generally these are included in the broker-dealers procedures document) to ensure they have appropriate program in place and/or obtain a certification from the broker-dealers AML Officer that they are in compliance with all BSA/AML regulatory requirements.
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#2199566 - 11/30/18 08:04 PM Re: Non deposit/investments department and BSA Megaman
Megaman Offline
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Joined: Jul 2017
Posts: 116
Hi Big Dog,

I think I am more inline with what you are saying. Do you have an annual review sheet that you would be willing to share or know where I can get one?

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#2199586 - 11/30/18 08:45 PM Re: Non deposit/investments department and BSA Megaman
Big Dog Offline
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You don't really need a form. I never used one, and not that I am on the audit side of things, I never see a form used. Just document the review and existence of the program pillars in a memo and keep it with a copy of the broker-dealers program. This should only be a once per year, 10 minute process.
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