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#546155 - 05/10/06 08:09 PM Policy checklists
Reed Offline
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Reed
Joined: Sep 2005
Posts: 1,251
West Coast
Does anyone have, or know where I can get, policy checklists for BSA/AML and/or CIP?

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BSA/AML/CIP/OFAC Forum
#546156 - 05/11/06 01:26 PM Re: Policy checklists
Kansayaku Offline
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Joined: Jan 2003
Posts: 1,454
metsuretsu
I don't have a specific checklist to offer you but I can tell you that I have found that if you go through the new Exam Manual for BSA, you can use the guidance in the area for what the program should include and incorporate each of the individual additional topics discussed, as applicable, as they correspond to your insititution. Other than this incorporate what you found in your risk assessment.
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#546157 - 05/12/06 12:39 PM Re: Policy checklists
Reed Offline
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Reed
Joined: Sep 2005
Posts: 1,251
West Coast
Thanks, I kind of did that.

We are a small FI in a small town no where near HIDTAs or HIFCAs and I'm just trying to figure out, do we need blurbs about NSL's, 314(b)(no, we don't participate), special measures, etc. or is the standard; SAR, CTR, MIL, CDD, OFAC, CIP okay for us.

If things don't really apply to us, can we ignore them or should we state that they don't apply or if they ever do apply, this is what we'll do, in our policy?

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#546158 - 05/12/06 01:17 PM Re: Policy checklists
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,458
Somewhere
I would not ignore them if you don't "do them". We don't share under 314A and did not have reference in our policy to 314A. The last time the FDIC was in, they stated that our BSA policy should include a reference that it exists and we don't currently participate but should we, we'll comply with the requirements.

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#546159 - 05/12/06 01:22 PM Re: Policy checklists
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
I agree with Pizza Queen... go through the exam guidelines and address each heading in the guidelines, in your policy, even if it is only to say that you don't have MSB's or you don't have International Shipments of Currency etc.

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#546160 - 05/12/06 01:44 PM Re: Policy checklists
Reed Offline
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Reed
Joined: Sep 2005
Posts: 1,251
West Coast
ok, thanks.

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