AML monitoring systems should be based upon each customer’s historical activity.

A Bank’s non-documentary customer identification procedures should address the following situations:

The most significant feature of the misuse of corporate vehicles is the hiding of the true beneficial ownership of the company.

Internal controls should:

Indicate which of the following types of pouch transactions from a foreign respondent bank are likely to: 1. be indicative of suspicious activity and should be further investigated; or 2. not be indicative of suspicious activity. The pouch includes $735 in U.S. currency.

Evaluating the risk of new accounts is an integral component of a viable BSA/AML compliance program. The following is a brief description of new accounts. All other things being equal, how would you rate the initial risk of each account: High, or low? The customer is the son of the head of a foreign embassy in your city. He is attending the university in your city and wishes to open an account to pay for his local expenses.

ACH transactions that are originated through a Third Party Service Provider (that is, when the Originator is not a direct customer of the ODFI) may increase BSA/AML risks, therefore, making it difficult for an ODFI to underwrite and review Originator transactions for compliance with BSA/AML rules

The scope of training should be functional, but bank-wide common must-know sessions are acceptable for everyone.

OFAC may grant general or specific licenses to engage in otherwise prohibited transactions

The bank’s BSA/AML risks when dealing with a processor account are similar to risks from correspondent banking relationships