--If, however, it is determined that further work is warranted, MODULE II The purpose of this module is to conduct on-site examination of teller operations relative to Financial Recordkeeping and Reporting Regulations. This module sets out procedures and guidelines the examiner should use when conducting test checks for compliance with the regulations. Criteria for selection of branches for detailed review are listed along with general guidelines applicable to either multiple or single office financial institutions. This phase of the examination should include a minimum of five (preferably ten or more) days of transactions and one to three branch offices. Branch examinations should encompass a review of the work of selected tellers within the days selected. The selection of tellers should be governed by the bank's internal procedures. For example, if it is the bank's practice to direct all large currency transactions to specific tellers, the examiner may concentrate on the work of those tellers. In the absence of such procedures, or if the procedures are not being followed, the work of all tellers should be reviewed. 1. 2. A REVIEW OF CURRENCY DISTRIBUTION/CASH CONTROL CENTER AND BRANCH a) Submit the Currency Distribution and Cash Control Center Letter b) If branches ship directly to a Federal Reserve Bank or a correspondent c) Check the records maintained at the currency distribution/cash control d) A Bank Office Letter should be personally addressed and sent to every branch. GUIDELINES FOR SELECTION OF BRANCHES FOR ON-SITE REVIEW a) In reviewing the information provided in the Currency Distribution Letter and Bank Office Letters, examiners should use the following criteria to select those branches for on-site review. (1) Branch requests for large denomination currency represent 3. 4. (2) Branch requests for large denomination currency are (3) Branch does not ship large denomination currency; (4) Branch reports no exempt list; (5) Branch manager would not sign the statement contained in the (6) Branch is characterized by unusual cash transactions with Cash Control Center, Federal Reserve Bank, or correspondent institution. b) In the absence of significant leads, consider selection of branches for on-site review by sampling on a random basis. GENERAL GUIDELINES FOR ON-SITE REVIEW a) When at the office location, the examiner is to review the work of b) Obtain, for selected tellers, completed cash proof sheets for as many consecutive dates as practical. From a day-to-day comparison of total $50 bills and $100 bills, determine specific tellers who experienced a significant ($10,000) fall-off in these denominations that is not supported by the tellers' transactions. Incidents of this type should be reported to management as possible incidents of currency washing. REVIEW PROCEDURES FOR SELECTED TELLERS AND SELECTED DATES a) Obtain and review tellers' documentation for the selected dates. b) Note any cash-in or cash-out transactions of more than $10,000. c) In instances where such transactions are discovered, determine the d) Review consecutive transactions which total in excess of $10,000 to ascertain if made by or for one depositor. . e) The following transactions should be checked: (1) Cashed checks items should be traced to ascertain if (2) Cash deposits any transaction involving the receipt of more than $10,000 cash. 5. (4) Personal money orders or official checks sold (8) Securities sold or purchased if institution acts as agent for an individual and the transaction involves more than $10,000 cash. f) The examiner should obtain and review the list of exempt List exceptions for possible inclusion in the report of examination. To facilitate our examination of compliance with Financial Recordkeeping and Examiner 1) A copy of your list of customers who are considered to be exempt from the reporting requirements of the Regulations. 2) Describe how currency transactions over $10,000 for customers are recorded and reported by individual tellers at your office. 3) Describe the records used at your office to document, by denomination, currency transfers between tellers, including transfer from and to vault cash. 4) Name of person in your office who is responsible for filing Currency Transaction Reports (Form 4789). 5) Indicate where copies of all Currency Transaction Reports (Form 4789) 6) A list of all transactions for which Currency Transaction Reports (Form 7) If periodic reviews are conducted by office management of exempt a) dates of last two reviews; b) description of work reviewed; c) names of individuals who conducted the review and their findings. Currency Transaction Reports (Form 4789) have been completed for all required transactions. A centralized list of exempt customers is currently maintained. In order to facilitate our review for compliance with Financial Recordkeeping and Reporting Regulations, please submit to the below-named examiner the following information. Supporting source records should be made available for review upon request. Examiner Please provide, according to the attached format, the following information for the period from inclusive. to 1) For offices which ship and receive currency through a central currency a) A list of all currency shipments between the distribution center and b) A list, by office, of all currency shipments between the distribution c) A list of currency shipments between offices; d) A list of offices which have shown a significant increase in their 2) For offices which transact (ship and/or receive currency) with the Federal Reserve Bank or correspondent institution, please provide: a) A list of all currency transactions between the office and the b) A list of all currency transactions with other offices. (Signed) (Title and Position) |