Assessing Compliance with BSA Regulatory Requirements
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.
- 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.
- 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.
- 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.
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.
- 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.
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