BSA EXAMINATIONS: PRIVATE BANKING

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BSA EXAMINATIONS PRIVATE BANKING

• John H. Atkinson
• February 9, 2005

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GENERAL EXPECTATIONS

• Assess and understand risks
• Design AML program to manage these risks
• Strong SAR process
• Senior management support
• Ongoing re-evaluation

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PRIVATE BANKING

• Enhanced Due Diligence
• Identify account holders and beneficial
  ownership
• Source of wealth / Source of funds
• PEP information
• Understand account structure, total
  relationship, and activity expectations
• Monitoring and reporting of suspicious
  activity

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PRIVATE BANKING

• Common Deficiencies
• Over-reliance on relationship manager
• Insufficient account documentation
• Weak client acceptance policy
• Poorly defined ongoing due diligence
  requirement

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PRIVATE BANKING

• Federal Reserve SR Letter 97-19
• Wolfsberg Principles and FAQs
• Proposed regulations for USAPA
• Section 312

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BSA EXAMINATIONS PRIVATE BANKING

• John H. Atkinson
• February 9, 2005