1. AML/BSA Certification Program Level I
COMMON AUDIT FINDINGS
SAR REPORTING
No evidence of compliance with 30/60 day time limit
Narratives did not communicate events clearly
Review for follow-up SAR not documented
Delayed review for follow-up SAR/SAR filed >90days
Technical omissions on follow-up SAR:
Earlier SAR not referenced
Reasons for not filing SAR not clearly documented
AML/BSA Certification Program Level I

2. AML/BSA Certification Program Level I
COMMON AUDIT FINDINGS
CTR REPORTING
Lack of aggregation of ALL currency transactions
ATM transactions excluded
System validation not performed by auditors
Accuracy of amounts reported open to question
Incorrect TIN reported
IRS Correspondence:
Inaccuracy of TIN on CTR, when CIF has correct TIN
Delays in responses
Exemptions:
Belief that ALL cash transactions are reasonable
AML/BSA Certification Program Level I

3. BSA/AML Policy & Program
COMMON AUDIT FINDINGS
BSA/AML Policy & Program
Approval not granted/documented by BOD
Lack of timely policy updates
Final Rules
FinCEN Guidance
AML/BSA Certification Program Level I

4. Customer Identification Program
COMMON AUDIT FINDINGS
Customer Identification Program
New accounts for existing customers without adequate KYC
No identification of accounts with missing TIN
Lack of physical address/accounts with only PO boxes
Violations of institutions P&P’s
Primary/secondary ID
KYC information
Documentation and sign-off
Non-timely review of new account documentation
AML/BSA Certification Program Level I

5. AML/BSA Certification Program Level I
COMMON AUDIT FINDINGS
AML Monitoring
Inadequate KYC information
Inadequate/excessive identification of “high risk” customers:
Inappropriate/canned risk rating model
No review of risk rating
Focused on “high risk customers”
No attention given to high risk products/services
No monitoring of activities not captured by AML systems
Sate Deposit Boxes
Trade Finance
AML/BSA Certification Program Level I

6. AML/BSA Certification Program Level I
COMMON AUDIT FINDINGS
AML Monitoring (cont.)
Monitoring procedures not documented
Adequacy of monitoring not addressed by Internal Audit
Lack of escalation procedures
Automated monitoring tool used without post-implementation validation for:
Adequacy of AML reports
Controls over AML system
Rationale for changes in monitoring parameters
Approval of changes
AML/BSA Certification Program Level I

7. AML/BSA Certification Program Level I
COMMON AUDIT FINDINGS
Training
Non coverage of ALL appropriate personnel
Training to specific to:
Role/function and products/services
No reference to policy and procedures
Employee’s failing tests:
No follow-up on low scores
The issue of repeat failures not addressed
Inadequate training for “new” BSA Officer
Senior mgmt and BOD not trained
AML/BSA Certification Program Level I