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Deposit brokers are generally considered high-risk as they can bundle deposits, obtain deposits from foreign customers, and facilitate anonymity of their depositors.

Due diligence policies, procedures and controls for Foreign Correspondent Banking must:

Commercial AML software systems are designed to be run “out of the box” and need no further tweaking to be effective.

Professional service providers (PSP) include lawyers, accountants, investment brokers, and doctors; generally all professionals who offer a service are PSP that can act as financial liaisons for their clients.

Examples of money laundering activity and suspicious activity monitoring and reporting can and should be tailored to each individual audience. Training should encompass information related to applicable business lines, such as trust services, international, and private banking.

A bank’s BSA/AML compliance program must:

Enterprise risk management effectively eliminates requirements for individual subsidiaries’ BSA/AML compliance programs, as they are folded into the enterprise risk management program.

In the following example indicate whether value is transferred to the 1. importer, or 2. exporter. Goods are priced as being of a value below their true value.

U.S. banks should obtain substantially the same information on its PTA customers whose transactions will pass through the U.S. bank as it obtains on its domestic customers.

ACH transactions that are originated through a Third Party Service Provider (that is, when the Originator is not a direct customer of the ODFI) may increase BSA/AML risks, therefore, making it difficult for an ODFI to underwrite and review Originator transactions for compliance with BSA/AML rules