1. BSA PROGRAM REQUIREMENTS

2.  Written, approved by the board of directors, and noted in the board minutes.  Based on the risk assessment  Fully implemented and reasonably designed to meet the BSA requirements  Practices must coincide with the credit union’s written policies, procedures, and processes GENERAL

3.  Internal controls  Independent testing  BSA officer  Training  A customer/member identification program (CIP) MINIMUM REQUIREMENTS

4. INTERNAL CONTROLS

5.  Policies, procedures, and processes  Based on risk INTERNAL CONTROLS

6.  Periodic updates to the BSA risk assessment.  Board reports of BSA activities including reports of SARs filed.  Procedures to ensure program continuity.  Member Due Diligence processes.  Identification of transactions that trigger reports or recordkeeping.  Procedures for filing reports. EXAMPLES OF INTERNAL CONTROLS

7.  Procedures for dual controls and the segregation of duties if possible.  Monitoring systems for timely detection and reporting of suspicious activity.  Supervision of employees that are involved in BSA reporting and recordkeeping.  Job descriptions that include BSA responsibilities.  Training program. EXAMPLES OF INTERNAL CONTROLS

8. INDEPENDENT TESTING

9.  Qualified tester  12 to 18 months  Report results to the board or supervisory committee INDEPENDENT TESTING

10.  Overall adequacy and effectiveness of the BSA/AML compliance program  A review of the credit union’s risk assessment  Transaction testing  Review of previous exam responses  A review of staff training for adequacy, accuracy, and completeness  Suspicious activity monitoring systems  Identification and reporting of suspicious activity  Management Information Systems (MIS) INDEPENDENT TESTING

11. BSA COMPLIANCE OFFICER

12.  Appointed by the board  Coordinates and monitors day-to- day BSA/AML compliance  BSA officer manages, but the board is ultimately responsible for compliance.  May delegate duties to others.  Sufficient authority and resources  Fully knowledgeable of the BSA and all related regulations.  Understand the credit union’s products and services  Must have the expertise, authority, or time to satisfactorily complete the job.  Report to board and senior management. BSA OFFICER

13. TRAINING

14.  Train appropriate personnel  Regulatory requirements and internal policies, procedures, and processes  Train all personnel involved with BSA  Train to specific responsibilities  New employee training  BSA officer training  Train management and the board  Incorporate current developments and changes to regulations and internal policies and processes  Document!  Keep records