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Standards for effective AML transaction testing

Question: 
What happens when a “BTT” is identified an a BSA exam?
Answer: 

Examiners will conduct testing of BSA monitoring programs. “BTT” refers to transactions that are below the threshold. Transactional testing will be done to verify that adequate parameters have been established for transactions above the line and below the line that has been established for monitoring. Enforcement actions have been issued when financial institutions allow the testing results to be driven by available staff resources rather than effective transaction testing.

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First published on 03/31/2019

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