BSA Risk Assessment Questionnaire Instructions: Utilize information from your BSA, OFAC and Member Identification policies to complete the BSA Risk Assessment Questionnaire. For the HIDTA/HIFCA analysis, utilize your most recent AIRES share file. The file can be edited to reflect only members with basic share accounts and sorted by zip code. Determine the county where each zip code is located and then compare against the HIDTA and HIFCA lists. Questionnaire: How often is the credit union’s entire membership checked against the OFAC SDN list? Does the credit union accept online membership applications? If yes, please provide details on procedures. Does the credit union accept online loan applications? If yes, please provide details on procedures. Does the credit union offer audio-response/telephone banking? If yes, please provide details on procedures for protecting member information. Does the credit union offer e-banking products (online banking, e-bill payment, mobile banking)? If yes, please provide details on procedures for protecting member information. Does the credit union review large transaction reports on a daily basis? If yes, what is the dollar threshold reviewed in a large transaction report? Are Currency Transaction Reports and Suspicious Activity Reports reviewed by management prior to submission? How many Currency Transaction Reports were submitted in 2010? How many CTRs have been submitted so far in 2011? How many Suspicious Activity Reports were submitted in 2010? How many SARs have been submitted so far in 2011? Does the credit union offer business accounts? If yes, has the credit union identified any high risk business accounts? How did the credit union make a determination that these accounts were high risk?
Does the credit union maintain a wire log for outgoing and incoming wires? If yes, is the log reviewed by management for suspicious patterns? How many incoming wires in 2010? How many incoming wires so far in 2011? How many outgoing wires in 2010? How many outgoing wires so far in 2011? How many international wires in 2010? How many international wires so far in 2011? Does the credit union have recurring wires such as payrolls or change funds? If yes, what percentage of incoming wires can be classified as recurring? Has credit union blocked debit card and credit card transactions with countries subject to OFAC sanctions (Cuba, Iran, Myanmar and Sudan)? Has credit union blocked debit card and credit card transactions with any other foreign countries? Please provide information on the number of years experience at the credit union for frontline staff members at each location. If relevant, please also provide information on experience at other financial institutions. Please also provide information on credit union/financial institution experience for key members of the management team.