ANSWERS(RATED A+)
As part of 314(a), CUs must conduct..... - ANSWERa 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: - ANSWER1. 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: - ANSWER• 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... - ANSWERthe 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... -
ANSWERcommensurate with the size, structure, risks, and complexity of the credit
union.
The BSA Officer is responsible for... - ANSWERcoordinating and monitoring day-to-day
BSA/AML compliance.
The BSA Officer is expected to... - ANSWERbe 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... - ANSWERthe
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... -
ANSWERbe involved in the function being tested, or audited.
The recommended frequency of the required independent testing... - ANSWERevery
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... -
ANSWERall personnel whose duties require knowledge of the BSA.
The CU's BSA/AML training should be... - ANSWERtailored to the person's specific
responsibilites.
While the board of directors (BOD) may not require the same degree of training as the
credit union's operations personnel, the BOD must understand... - ANSWERthe
importance of BSA regulatory requirements, the ramifications of noncompliance, and
the risks posed to the credit union.
Who is ultimately responsible for the CU's BSA/AML compliance? - ANSWERThe Board
of Directors
NCUA recommends that BSA training be done... It should also be... - ANSWERevery 12
to 18 months. It should also be ongoing and incorporate current developments and
changes.
CUs are required to have appropriate ___ procedures for conducting ongoing member
due diligence. - ANSWERrisk-based
Before a CU may create appropriate MDD procedures, it must first... - ANSWERdevelop
a member risk profile.
Developing a member risk profile means/requires... - ANSWERunderstanding the
nature and purpose of each member relationship as well as expected transaction
activity, in order to provide a baseline against which your member's activity is assessed
for suspicious activity reporting.
Establishing a member risk profile may include... - ANSWER1. 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... -
ANSWERthe member's risk profile.
On what basis must CUs maintain and update member information? - ANSWERon a
risk-basis.
On what basis are CUs not required to update member information? - ANSWERon a
continuous or periodic basis.
The member information updating requirement is ____ driven and only occurs as a
result of what? - ANSWER1. Event
2. detecting unusual activity through normal monitoring.
, Ongoing due diligence monitoring applies to... - ANSWERALL of your members
Ongoing due diligence monitoring helps you.... - ANSWERdetermine whether a member
is or isn't "higher risk".
When identifying members as higher-risk, CUs may not... - ANSWERlabel any particular
category of businesses as "high-risk"
The level of risk for each individual account must be determined by... -
ANSWERperforming 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... - ANSWERenhanced due diligence for this account.
The CU's BSA/AML Compliance Program must include a CIP/MIP to... -
ANSWEReffectively 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? -
ANSWERevery member/customer opening an account.
Every part of the BSA/AML Compliance Program (including the BSA/AML policies &
procedures) must correspond with... - ANSWERthe unique risk profile of the specific
credit union.
The development of the credit union's BSA/AML risk assessment generally involves... -
ANSWER1. 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... - ANSWERall pertinent
information.
(T/F) The required risk-categories include: products, services, members, and
geographic locations of each of the CU's offices. - ANSWERFalse. There are no
required risk categories.
The number and detail of a CU's risk-categories will vary based on... - ANSWERthe
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. - ANSWERFalse. Any single indicator does not necessarily determine the
existence of lower or higher risk.