ESSENTIAL BSA DUTIES AND RESPONSIBILITIES

·        Ensure the ongoing development and implementation of an anti-money laundering compliance program and review and monitoring of policies and procedures to ensure compliance with applicable Federal and state laws and regulations.

·        Develop and implement a periodic BSA compliance review program of banking activities, concentrating on the higher risk areas of the Bank.  Report results to Management and the Audit

·        Committee and follow up on corrective action required and implementation of recommendations.

• Formulate, implement and evaluate the training and awareness programs to strengthen understanding of BSA compliance.  The BSA Officer will train bank associates on existing requirements as well as changes to laws, rules and regulations.  This may be done either by the BSA officer or with the assistance of legal counsel or vendors.


• Ensure that implications relating to BSA compliance issues identified are properly recognized and appropriate action plans are agreed and implemented.


• Utilize user defined AML reports to detect suspicious activity trends.  Investigate account exceptions to conclude activity is consistent with the customer profile and state purpose of account or further investigation required.


• Investigate accounts surpassing variance parameters as detected by the AML program.  By utilizing the AML tools, perform checks by sampling customer accounts to validate that the actual activity is in accordance with the expected activity provided by the customer.


• Review selected new account files to determine that adequate due diligence and profiling is being performed and interact with account officers on KYC profiling deficiencies detected during the due diligence exercise.


• Underwrite Suspicious Activity Reports, when required.

• Monitor and track large currency transactions against the Cash Log and Currency Shipment


• Reports to ensure transactions requiring a CTR are filed accurately and timely.


• Monitor responses to correspondence received from the Internal Revenue Service.


• Monitor customers designated as “exempt persons” from the large currency transaction reporting requirements.


• In accordance with Section 314(a) under the USA Patriot Act, research names provided by FinCEN against the bank system of accounts and historical activity for possible matches.  Handle the process for reporting positive matches.


• Daily review of OFAC website under the section “Recent OFAC Actions” to ascertain updated entries on the OFACs SDN list.  Monitor to ensure new names are added to the OFAC Bridger application and conduct a run against the portfolio of accounts to determine any possible matches.


• Daily review of systems to check possible OFAC matches on incoming/outgoing wire transfers and clear items that are deemed mismatch hits.


• Prepare monthly BSA Activity memorandum reports to the Bank’s Audit Committee.


• Additional Compliance Responsibilities.