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INDEPENDENT AUTOMATED TELLER MACHINE OWNERS OR …

INDEPENDENT AUTOMATED TELLER MACHINE OWNERS or Operators FFIEC BSA/AML Examination Manual 1 November 2021 INDEPENDENT AUTOMATED TELLER MACHINE OWNERS OR OPERATORS Objective: Evaluate the bank s policies, procedures, and processes to assess, manage, and mitigate potential risks associated with customers who are INDEPENDENT AUTOMATED TELLER MACHINE (ATM) OWNERS or operators, including INDEPENDENT Sales Organizations (ISOs). Evaluate the bank s compliance with regulatory requirements, such as customer identification, customer due diligence (CDD), beneficial ownership of legal entity customers, currency transaction reporting, and suspicious activity reporting with respect to these customers.

risk of money laundering, terrorist financing (ML/TF), or other illicit financial activity. Further, banks that operate in compliance with applicable Bank Secrecy Act/anti-money laundering (BSA/AML) regulatory requirements and reasonably manage and mitigate risks related to the unique characteristics of customer relationships are neither prohibited

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Suspicious Activity Reporting — Overview

bsaaml.ffiec.gov

Suspicious activity reporting forms the cornerstone of the BSA reporting system. It is critical to the United States’ ability to utilize financial information to combat terrorism, terrorist financing, money laundering, and other financial crimes. Examiners and banks should

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Overview - Federal Financial Institutions Examination Council

bsaaml.ffiec.gov

FFIEC BSA/AML Examination Manual 236 2/27/2015.V2 behalf of the customer’s clients. When the bank is unable to identify and understand the nature and source of the transactions processed through an account, the risks to the bank and the likelihood of suspicious activity can increase. If a bank has not implemented an adequate

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POLITICALLY EXPOSED PERSONS

bsaaml.ffiec.gov

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Overview - Federal Financial Institutions Examination Council

bsaaml.ffiec.gov

The regulatory interpretation states that, for purposes of 1010.410(f), the term “address” means either the transmittor’s street address or the transmittor’s address maintained in the financial institution’s automated CIF (such as a mailing address including a post office box)

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2014 FFIEC Bank Secrecy Act/Anti-Money Laundering ...

bsaaml.ffiec.gov

Bank Secrecy Act/ Anti-Money Laundering Examination Manual . Federal Financial Institutions Examination Council . Board of Governors of the Federal Reserve System, Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, National Credit Union Administration, Office of the Comptroller of the Currency, State Liaison Committee ...

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Nonbank Financial Institutions — Overview

bsaaml.ffiec.gov

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CURRENCY TRANSACTION REPORTING

bsaaml.ffiec.gov

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CUSTOMER IDENTIFICATION PROGRAM

bsaaml.ffiec.gov

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PURCHASE AND SALE OF CERTAIN MONETARY …

bsaaml.ffiec.gov

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BSA/AML Independent Testing - 508

bsaaml.ffiec.gov

lower-risk profiles for ML/TF and other illicit financial activities may consider utilizing a shared resource as part of a collaborative arrangement to conduct independent testing. 2. ... For detailed information on collaborative arrangements see “ Interagency Statement on Sharing Bank Secrecy Act Resources,” issued by Federal Reserve, FDIC ...

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Final Report - European Banking Authority

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esas-joint-committee.europa.eu

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