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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.

conducting ongoing monitoring to identify and report suspicious activity. Moreover, performing an appropriate level of ongoing CDD commensurate with the customer’s risk profile assists the bank in determining whether a customer’s transactions are suspicious.

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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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CURRENCY TRANSACTION REPORTING

bsaaml.ffiec.gov

31 CFR 1020.320(a)(2)(ii). 15. 31 CFR 1010 Subpart H. Currency Transaction Reporting FFIEC BSA/AML Examination Manual 4 February 2021 . Filing and Record Retention . All CTRs must be filed through . FinCEN’s BSA E-Filing System. 16 Certain fields in the CTR

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Overview - Federal Financial Institutions Examination Council

bsaaml.ffiec.gov

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bsaaml.ffiec.gov

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Overview - Federal Financial Institutions Examination Council

bsaaml.ffiec.gov

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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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bsaaml.ffiec.gov

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bsaaml.ffiec.gov

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PURCHASE AND SALE OF CERTAIN MONETARY …

bsaaml.ffiec.gov

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bsaaml.ffiec.gov

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www.fincen.gov

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bsaaml.ffiec.gov

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FDIC Bank Secrecy Act

www.fdic.gov

Suspicious Activity Reports (SARs) Banks have a responsibility to monitor, identify, and report suspicious activity If made aware of unusual or suspicious activity, a bank must investigate to determine if a SAR should be filed Banks are not responsible for finding evidence or proving crime

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www.ffiec.gov

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