BSACS QUESTIONS AND ANSWERS
As part of 314(a), CUs must conduct..... - Answers :a one-time search of its records to
identify accounts or transactions of a named suspect. Unless otherwise instructed by an
information request, search records for: current accounts; accounts maintained during
the preceding 12 months; and transactions conducted outside of an account by or on
behalf of a named suspect during the preceding six months.
Bank Secrecy Act/Anti-Money Laundering (BSA/AML) regulations require credit unions'
BSA/AML Compliance Programs to include, at a minimum: - Answers :1. A qualified
BSA compliance officer; 2. A system of internal controls; 3. Independent testing; 4.
Training for all appropriate personnel; and 5. Ongoing member due diligence.
Credit unions' compliance programs must be: - Answers :• in writing, • approved by the
credit union's board of directors, and • reflected in the minutes of the board meeting.
A "system of internal controls" refers to... - Answers :the policies and procedures the
credit union puts in place to limit and control risks associated with BSA/AML.
The level of sophistication of the credit union's internal controls will be... - Answers
:commensurate with the size, structure, risks, and complexity of the credit union.
The BSA Officer is responsible for... - Answers :coordinating and monitoring day-to-day
BSA/AML compliance.
Establishing a member risk profile may include... - Answers :1. self evident information
(such as type of member, acct, service, or product)
2. ongoing monitoring to identify changes (ex: member activity changes)
Activity changes (such as transaction activity or beneficial ownerships) could impact... -
Answers :the member's risk profile.
On what basis must CUs maintain and update member information? - Answers :on a
risk-basis.
On what basis are CUs not required to update member information? - Answers :on a
continuous or periodic basis.
The member information updating requirement is ____ driven and only occurs as a
result of what? - Answers :1. Event
2. detecting unusual activity through normal monitoring.
Ongoing due diligence monitoring applies to... - Answers :ALL of your members
Ongoing due diligence monitoring helps you.... - Answers :determine whether a member
is or isn't "higher risk".
,When identifying members as higher-risk, CUs may not... - Answers :label any particular
category of businesses as "high-risk"
The level of risk for each individual account must be determined by... - Answers
:performing a risk assessment unique to each account.
If the credit union determines that a member or account presents a higher risk, the
credit union must perform... - Answers :enhanced due diligence for this account.
The CU's BSA/AML Compliance Program must include a CIP/MIP to... - Answers
:effectively identify and verify the identity of every member and customer opening an
account.
The CU's MIP/CIP requires the CU to identify and verify the identity of who? - Answers
:every member/customer opening an account.
Every part of the BSA/AML Compliance Program (including the BSA/AML policies &
procedures) must correspond with... - Answers :the unique risk profile of the specific
credit union.
The development of the credit union's BSA/AML risk assessment generally involves... -
Answers :1. the identification of specific risk categories unique to the CU
2. an analysis of the information identified to better assess the risks within these specific
risk categories.
The identification of risk categories is credit union-specific, and a conclusion regarding
the risk categories should be based on the consideration of... - Answers :all pertinent
information.
(T/F) The required risk-categories include: products, services, members, and
geographic locations of each of the CU's offices. - Answers :False. There are no
required risk categories.
The number and detail of a CU's risk-categories will vary based on... - Answers :the
CU's size or complexity, and organizational structure.
T/F: The existence of a single indicator can determine the existence of lower or higher
risk. - Answers :False. Any single indicator does not necessarily determine the
existence of lower or higher risk.
The purpose of the Risk Assessment analysis is to assess... in order to... - Answers :1.
Money Laundering/Terrorist Financing (ML/TF) and other illicit financial activity risks
2. develop appropriate internal controls to mitigate overall risk.
The credit union's risk assessment must be... - Answers :1. Very comprehensive,
, 2. in writing
3. Provided to all business lines across the credit union.
An effective risk assessment should be... not... - Answers :an ongoing process, not a
one-time exercise.
The federal regulators recommend reassessing the BSA risk... - Answers :at least every
12 to 18 months.
T/F: The credit union's BSA Officer is ultimately responsible for the credit union's BSA
compliance. - Answers :False. The BOD is ultimately responsible for the CU's
compliance.
The BSA Officer must be knowledgeable of:
a. The BSA, and related regulations;
b. The credit union's products and services;
c. The credit union's members;
d. The credit union's neighborhoods;
e. a & b
f. All of the above. - Answers :f. All of the above.
T/F: If you are a small credit union (less than $100 million) it is acceptable to have the
BSA Officer identify when BSA related reports must be filed, fill out the reports, and
determine when members are eligible to be exempt from BSA reporting. - Answers
:False.
The BSA Officer is expected to... - Answers :be fully knowledgeable of the Bank
Secrecy Act and all related regulations, as well as understand the money laundering
and terrorist financing risks associated with each of the credit union's products,
services, members, and geographic locations.
An audit of the BSA/AML compliance program should be conducted by... - Answers :the
internal audit department, outside auditors, consultants, or other qualified independent
parties.
While the auditor must be qualified to test BSA compliance, he or she may not... -
Answers :be involved in the function being tested, or audited.
The recommended frequency of the required independent testing... - Answers :every
12-18 months, depending on the credit union's risk profile.
At a minimum, the credit union's BSA/AML training program must provide training for... -
Answers :all personnel whose duties require knowledge of the BSA.
The CU's BSA/AML training should be... - Answers :tailored to the person's specific
responsibilites.
As part of 314(a), CUs must conduct..... - Answers :a one-time search of its records to
identify accounts or transactions of a named suspect. Unless otherwise instructed by an
information request, search records for: current accounts; accounts maintained during
the preceding 12 months; and transactions conducted outside of an account by or on
behalf of a named suspect during the preceding six months.
Bank Secrecy Act/Anti-Money Laundering (BSA/AML) regulations require credit unions'
BSA/AML Compliance Programs to include, at a minimum: - Answers :1. A qualified
BSA compliance officer; 2. A system of internal controls; 3. Independent testing; 4.
Training for all appropriate personnel; and 5. Ongoing member due diligence.
Credit unions' compliance programs must be: - Answers :• in writing, • approved by the
credit union's board of directors, and • reflected in the minutes of the board meeting.
A "system of internal controls" refers to... - Answers :the policies and procedures the
credit union puts in place to limit and control risks associated with BSA/AML.
The level of sophistication of the credit union's internal controls will be... - Answers
:commensurate with the size, structure, risks, and complexity of the credit union.
The BSA Officer is responsible for... - Answers :coordinating and monitoring day-to-day
BSA/AML compliance.
Establishing a member risk profile may include... - Answers :1. self evident information
(such as type of member, acct, service, or product)
2. ongoing monitoring to identify changes (ex: member activity changes)
Activity changes (such as transaction activity or beneficial ownerships) could impact... -
Answers :the member's risk profile.
On what basis must CUs maintain and update member information? - Answers :on a
risk-basis.
On what basis are CUs not required to update member information? - Answers :on a
continuous or periodic basis.
The member information updating requirement is ____ driven and only occurs as a
result of what? - Answers :1. Event
2. detecting unusual activity through normal monitoring.
Ongoing due diligence monitoring applies to... - Answers :ALL of your members
Ongoing due diligence monitoring helps you.... - Answers :determine whether a member
is or isn't "higher risk".
,When identifying members as higher-risk, CUs may not... - Answers :label any particular
category of businesses as "high-risk"
The level of risk for each individual account must be determined by... - Answers
:performing a risk assessment unique to each account.
If the credit union determines that a member or account presents a higher risk, the
credit union must perform... - Answers :enhanced due diligence for this account.
The CU's BSA/AML Compliance Program must include a CIP/MIP to... - Answers
:effectively identify and verify the identity of every member and customer opening an
account.
The CU's MIP/CIP requires the CU to identify and verify the identity of who? - Answers
:every member/customer opening an account.
Every part of the BSA/AML Compliance Program (including the BSA/AML policies &
procedures) must correspond with... - Answers :the unique risk profile of the specific
credit union.
The development of the credit union's BSA/AML risk assessment generally involves... -
Answers :1. the identification of specific risk categories unique to the CU
2. an analysis of the information identified to better assess the risks within these specific
risk categories.
The identification of risk categories is credit union-specific, and a conclusion regarding
the risk categories should be based on the consideration of... - Answers :all pertinent
information.
(T/F) The required risk-categories include: products, services, members, and
geographic locations of each of the CU's offices. - Answers :False. There are no
required risk categories.
The number and detail of a CU's risk-categories will vary based on... - Answers :the
CU's size or complexity, and organizational structure.
T/F: The existence of a single indicator can determine the existence of lower or higher
risk. - Answers :False. Any single indicator does not necessarily determine the
existence of lower or higher risk.
The purpose of the Risk Assessment analysis is to assess... in order to... - Answers :1.
Money Laundering/Terrorist Financing (ML/TF) and other illicit financial activity risks
2. develop appropriate internal controls to mitigate overall risk.
The credit union's risk assessment must be... - Answers :1. Very comprehensive,
, 2. in writing
3. Provided to all business lines across the credit union.
An effective risk assessment should be... not... - Answers :an ongoing process, not a
one-time exercise.
The federal regulators recommend reassessing the BSA risk... - Answers :at least every
12 to 18 months.
T/F: The credit union's BSA Officer is ultimately responsible for the credit union's BSA
compliance. - Answers :False. The BOD is ultimately responsible for the CU's
compliance.
The BSA Officer must be knowledgeable of:
a. The BSA, and related regulations;
b. The credit union's products and services;
c. The credit union's members;
d. The credit union's neighborhoods;
e. a & b
f. All of the above. - Answers :f. All of the above.
T/F: If you are a small credit union (less than $100 million) it is acceptable to have the
BSA Officer identify when BSA related reports must be filed, fill out the reports, and
determine when members are eligible to be exempt from BSA reporting. - Answers
:False.
The BSA Officer is expected to... - Answers :be fully knowledgeable of the Bank
Secrecy Act and all related regulations, as well as understand the money laundering
and terrorist financing risks associated with each of the credit union's products,
services, members, and geographic locations.
An audit of the BSA/AML compliance program should be conducted by... - Answers :the
internal audit department, outside auditors, consultants, or other qualified independent
parties.
While the auditor must be qualified to test BSA compliance, he or she may not... -
Answers :be involved in the function being tested, or audited.
The recommended frequency of the required independent testing... - Answers :every
12-18 months, depending on the credit union's risk profile.
At a minimum, the credit union's BSA/AML training program must provide training for... -
Answers :all personnel whose duties require knowledge of the BSA.
The CU's BSA/AML training should be... - Answers :tailored to the person's specific
responsibilites.
