Bank Secrecy Act |
EXAMINATION PROCEDURES
Foreign Bank and Financial Accounts Reporting
Objective. Assess the bank’s compliance with statutory and regulatory requirements for the reporting of foreign bank and financial accounts.
1. Determine whether the bank has a financial interest in, or signature authority over, bank, securities, or other financial accounts in a foreign country, or whether the bank is otherwise required to file a Report of Foreign Bank and Financial Accounts (FBAR) (TD F 90-22.1) form for trust customers.
2. If applicable, review the bank’s policies, procedures, and processes for filing annual reports.
Transaction Testing
3. On the basis of a risk assessment, prior examination reports, and a review of the bank’s audit findings, select a sample of accounts to determine whether the bank has appropriately completed, submitted, and retained copies of the FBAR forms.
4. On the basis of examination procedures completed, including transaction testing, form a conclusion about the ability of policies, procedures, and processes to meet regulatory requirements associated with FBARs.
