COMMON AUDIT FINDINGS
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COMMON AUDIT FINDINGS SAR REPORTING No evidence of compliance with 30/60 day time limit - PowerPoint PPT Presentation


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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

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COMMON AUDIT FINDINGS SAR REPORTING No evidence of compliance with 30/60 day time limit

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  • 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


  • 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


  • 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


  • 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


  • 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


  • 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


  • 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


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