BSA/AML Manual

INTERNATIONAL TRANSPORTATION OF CURRENCY OR MONETARY INSTRUMENTS REPORTING EXAMINATION AND TESTING PROCEDURES

Objective: Assess the bank’s compliance with the BSA regulatory requirements for the reporting of international shipments of currency or monetary instruments.

1. Determine whether the bank has (or has caused to be) physically transported, mailed, or shipped currency or other monetary instruments in excess of $10,000, at one time, into or out of the United States, or whether the bank has received currency or other monetary instruments in excess of $10,000, at one time, that has been physically transported, mailed, or shipped into the United States.
2. Review the bank’s policies, procedures, and processes for identifying reportable international shipments of currency or monetary instruments and for filing a Report of International Transportation of Currency or Monetary Instruments (CMIR) to determine whether they meet the BSA regulatory requirements for CMIR reporting.
3. Determine whether the bank’s policies, procedures, and processes (internal controls) are designed to assure ongoing compliance with CMIR filing requirements and are commensurate with the bank’s risk profile.
4. Select a sample of reportable transactions and filed CMIRs and determine whether:
   • CMIRs are filed in accordance with FinCEN form instructions.
   • CMIRs filed contain accurate and complete information.
   • CMIRs are filed at the time of entry into the United States or at the time of departure, mailing, or shipping from or into the United States.
   • Any discrepancies exist between the bank’s records of CMIRs and the CMIRs reflected in the BSA reporting database.
   • The bank has taken corrective action when errors are identified.
   • The bank retains copies (electronic format or paper copies) of CMIRs for five years from the date of the report.
5. On the basis of examination and testing procedures completed, form a conclusion about the adequacy of policies, procedures, and processes the bank has developed to meet BSA regulatory requirements associated with CMIRs.