Assessing Compliance with BSA Regulatory Requirements
Purchase and Sale of
Monetary Instruments Recordkeeping
Objective. Assess the bank’s compliance with statutory and regulatory requirements for the recording of information required for the purchase and sale of monetary instruments for currency in amounts between $3,000 and $10,000, inclusive. This section covers the regulatory requirements as set forth by the BSA. Refer to the expanded sections of this manual for additional discussions and procedures on specific money laundering risks for purchase and sale of monetary instruments activities.
1. Determine whether the bank maintains the required records (in a manual or an automated system) for sales of bank checks or drafts including foreign drafts, cashier’s checks, money orders, and traveler’s checks for currency in amounts between $3,000 and $10,000, inclusive, to purchasers who have deposit accounts with the bank.
2. Determine whether the bank’s policies, procedures, and processes permit currency sales of monetary instruments to purchasers who do not have deposit accounts with the bank (nondepositors):
- If so, determine whether the bank maintains the required records for sales of monetary instruments to nondepositors.
- If not permitted, determine whether the bank allows sales on an exception basis.
3. On the basis of a risk assessment, prior examination reports, and a review of the bank’s audit findings, select a sample of monetary instruments sold for currency in amounts between $3,000 and $10,000, inclusive, to determine whether the bank obtains, verifies, and retains the required records to ensure compliance with regulatory requirements.
4. On the basis of examination procedures completed, including transaction testing, form a conclusion about the ability of policies, procedures, and processes to meet regulatory requirements associated with the purchase and sale of monetary instruments.
5. On the basis of the previous conclusion and the risks associated with the bank’s activity in this area, proceed to expanded examination procedures, if necessary.
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