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Wisconsin Credit Union Foundation

Job-Specific BSA for Deposit Operations: SAR Monitoring, 314(a) Requests & CIP

Get the skills you need on the three areas that are focal points of transaction testing sections of the BSA exam process.

Aug 16, 2017 02:00 PM   -­­  Aug 16, 2017 03:30 PM


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Type of Event
On Demand Webinar

Who Should Attend
  • On Demand
  • Webinars
  • Member Services
  • Compliance



Deposit operations staff must have effective, ongoing training to support several critical BSA requirements. This webinar will focus on three areas that are focal points of transaction testing sections of the BSA exam process. Real-life examples of suspicious activities detected by deposit operations staff will be included, along with practical tips for processing and protecting the confidentiality of time-sensitive 314(a) requests. In addition, examiners have been closely monitoring CIP compliance and many financial institutions have been surprised by the findings. This session will include examples of CIP deficiencies in recent BSA enforcement actions and provide additional monitoring tools for deposit operations staff.

Learning Objectives

  • When an account is opened, what does the frontline need to know regarding customer due diligence (CDD), enhanced due diligence (EDD), and beneficial ownership?
  • Risk assessment best practices for CDD and EDD in 2017 – and 2018 changes
  • Tips for monitoring an effective CIP, including case studies
  • Recent enforcement actions on failure to identify, monitor, and report suspicious activity
  • Tips for deposit operations staff to avoid five violation areas
  • Seven steps that should be included in 314(a) procedures
    • Designation of a contact person
    • Notification process
    • Record search
    • Review of potential matches – how are positive matches reported to FinCEN?
    • What types of escalation are required for potential matches and investigation?
    • Confidentiality requirements
    • Best practices for documentation and record retention


Susan Costonis, Compliance Consulting and Training for FIs

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