Bank Secrecy Act (BSA) High-Risk Entities Identifying ...

1 This tool has been printed fromBanker Tools on Secrecy Act (BSA)High-RiskEntitiesIdentifying WorksheetsThe following informationshould provide guidance forcompletionofworksheets: High-RiskEntities Identified Worksheet High-RiskEntities Excluded Worksheet Structuring MonitoringWorksheetHigh-RiskEntities Identified &/orExcluded ReviewAlthough attempts tolaunder money through a legitimate financial institution can emanate frommanydifferent sources, certainkinds of businesses, transactions, or geographic locations may lend themselvesmore readily than others topotential criminal activity.

2 While conducting your customer review, focus in onthe following examplesthat couldbe a potential source of money laundering and are considered a High-Risk entity while not excluding other types of risk such as potential kiting. Completethe High-RiskEntities Included and/or High-Risk EntitiesExcluded accordingly. High-Risk Examples include:Businesses Nontraditional financialentities, such as: Currency exchange houses, also known as giros or casas de cambio. money transmitters. Check cashing facilities. Casinos and card clubs.

3 Offshore corporations and banks locatedintax and/or Secrecy havens. Leather goods stores. Car, boat, and plane dealerships. Used automobile or truck dealers and machine parts manufacturers. Travel agencies. Brokers/dealers. Jewel, gem, and precious metal dealers. Import/export companies. Auctioneers. Deposit brokers. Pawn brokers. Professional serviceproviders (lawyers, accountants, investment brokers). Cash-intensive businesses, such as convenience stores, restaurants, retailstores, and parking garages. Ship, bus, and plane operators.

4 Functions and transactions Private banking. Trust departments. Offshore international activity. Deposit-taking facilities. International correspondent banking activity. Internet banking. Wire transfers/cash management functions. Transactions inwhich the primary beneficiary or counterparty is undisclosed. Loan guaranteeschemes. Transactions involving large amounts of traveler s checks, official bank checks, money orders, andstored value cards. Pouch tool has been printed fromBanker Tools on Electronic transactions that permit the rapidmovement of currency ( , foreign exchange transactionsfollowed by payment intoanother jurisdiction).

5 Trade financing transactions with unusual pricing Countriesin whichthe production or transportation of illegal drugs may be taking place. Bank Secrecy havens. Emerging countriesthat may be seeking hard currency investments. CountriesidentifiedinFinCEN advisories. Major money laundering countriesand Review31 CFR states, a person structures a transaction if that person, acting alone, in conjunction with oron behalf of others, conducts or attempts toconduct one or more transactions in currency at one or morefinancial institutions, on one or more days, in any manner, for the purpose of evading the CTR filingrequirements.

6 In any manner, includes, but is not limited tobreaking down a single currency sumexceeding $10,000 dollars intosmaller amounts, that may be conductedas a seriesof transactions at or lessthan $10,000. The transaction(s) need not exceed the $10,000 CTR filing thresholdat any one financialinstitution on any single day in order toconstitute structuring. All attempts toevade the BSA CTR filing requirements for cash transactions that exceed $10,000 (31 CFR ) are criminal and civil violations of the BSA regulations. Under the BSA, no person shall,to evade the CTR reporting Structuring Review Worksheet is tobe used for potential structuring of funds.

7 Procedures tobeutilized are as follows:Review a minimumof three High-Risk Entities the Large Cash Transaction Report .Log and review items under the $10,000 thresholdfor each entity monitored for the note:To be compliant with BSA requirements, banks shouldalso monitor transactions for Non-Bank FinancialInstitution (NBFI) and money Services Business (MSB) identified high risk entity that is a NBFI should be reviewed quarterlyfor activity that wouldqualify as an MSB or a Non Bank Financial Institution, and if it is determined the Non Bank FinancialInstitution IS an MSB, appropriate due diligence should be tool has been printed fromBanker Tools on NameBank Secrecy Act (BSA)

8 High-Risk Entities IdentifiedIncludes Non-Bank Financial Institutions & money Services BusinessesBranch Location: _____Date: _____ Signature: _____Date IdentifiedCustomer IdentifiedAccount NumberReason IdentifiedThis tool has been printed fromBanker Tools on NameBank Secrecy Act (BSA) High-Risk Entities ExcludedIncludes Non-Bank Financial Institutions & money Services BusinessesBranch Location: _____Date: _____ Signature: _____DateExclusionCustomer ExcludedAccount NumberReason ExcludedThis tool has been printed fromBanker Tools on NameBank Secrecy Act (BSA) Structuring Monitoring WorksheetIncludes Non-Bank Financial Institutions & money Services BusinessesBranch Location: _____Date: _____ Signature: _____This worksheet is tobe used for potential structuring of funds.

9 Review a minimumof three High-Risk Entities identified. Utilize the Large Cash Transaction Report . Log and review items under the $10,000 thresholdfor each entity monitored for the TransactionCustomer (Entity)Account Number/Type of TransactionDollar Amount