Bennett Quillen – Bank Secrecy Lookback Guidelines
by Bennett Quillen
Background: Lookback covers the period mm/dd/yyyy through mm/dd/yyyy. The inventory of accounts to be reviewed is TBD. We will review 100% of HIGH, 50% of Medium and a statistical sampling of the LOW.
Currently we have about nnn accounts rated HIGH (business and retail). All other risk ratings in the ITI system are suspect. Therefore the Bank is doing a Risk Rating Form for each business transaction account. That is in process. (See the risk rating tool included as a separate doc). This is the rating we will use to identify the number of HIGH, MEDIUM and LOW risk accounts. In addition we will review Cash transaction from Patriot Officer (PO) and wire transfers to identify any other accounts that appear to need review and include them if they are not already included.
1) The risk rating sheet is the primary sheet. No file can be counted unless this is completed. It must be completed by the Bank as part of the Lookback is to validate the quality of the risk rating process. So any changes we recommend, whether raise or lower must be noted. When a consultant takes a risk rating sheet they are responsible for the entire relationship, as shown on the Portfolio printout from ITI.
2) We may need to adjust the Account review Cover Sheet as well as the Lookback Spreadsheet, as we should have better data from patriot Officer on Cash transactions. A report for each account can be generated which shows all cash transactions.
3) We will still need to test some deposits and obtain documentation in order to validate that deposits with cash show the cash in PO, and deposits with no cash show there is no transaction in PO.
4) CTRs should be sampled as deemed appropriate. Be aware of days with multiple transactions and test more of those. Check against the CT filed report. Also test by getting a copy of the CTR as some may be more complex with multiple parties. The number of CTRs tested per account should be tracked and any exceptions noted.
5) Each account review must identify who prepared it and it must be reviewed by another consultant. Any suspicious activity identified must be referred to the managing consultant or the Director.
6) These are guidelines and likely will need to be modified as we progress. Our day-to day contact will be the BSA Officer.