Banks are required to investigate suspected underlying crimes on which they file SARs.

When considering an institution’s geographic money laundering risk factor, countries sanctioned by OFAC are only important to a US financial institution

Training should encompass information related to applicable business lines, as well as changes to internal policies, procedures, processes, and monitoring systems.

When structuring the BSA/AML compliance function, authority and independence are not of interest

Consolidated information assists senior management and the board of directors in understanding and appropriately mitigating risks across the organization.

Given that e-banking transactions are processed through high levels of technology they need not be subjected to EDD

When analyzing trade transactions for unusual or suspicious activity, banks need not consider reviewing or becoming familiar with copies of official government import and export forms to assess the reliability of documentation provided

A common AML risk associated with e-banking products is that transactions are instantaneous

Any entity that engages in money transmission in any amount is subject to the BSA rules. This also applies to certain foreign-located persons engaging in MSB activities within the U.S.

Even though trade finance services have been widely associated with money laundering and terrorist financing activity, there have been no industry standards or guidance issued on this matter