3 MODERATE: moderate volume of large currency or structured transactions HIGH: significant volume of large currency or structured transactions
filed. CTRs and SARs are reviewed by upper management prior to submission. Wire log is kept.
ASSIGN RISK LEVEL BASED ON NUMBER OF LARGE CURRENCY OR STRUCTURED TRANSACTIONS.
High-risk Customers and Businesses
INCLUDE THE FOLLOWING INFORMATION: The credit union had ___ CTRs and ____ SARs during 2009. There are ____ exempt businesses. LOW: Few high-risk customers and businesses MODERATE: Moderate number of high-risk customers and businesses HIGH: Large number of high-risk customers and businesses
Foreign Correspondent Financial Institution Accounts
LOW: No foreign customer correspondent financial institution accounts. The credit union does not engage in pouch activities, offer special-use accounts, offer payable through accounts (PTAs), or provide U.S. dollar draft services. CREDIT UNIONS TYPICALLY DO NOT OFFER THESE SERVICES, SO RISK LEVEL TYPICALLY WILL BE LOW
DESCRIBE MITIGATION FACTORS IF CREDIT UNION HAS IDENTIFIED HIGHRISK CUSTOMERS AND BUSINESSES IF NONE, STATE NO MITIGATION NEEDED AS CREDIT UNION DOES NOT HAVE HIGH-RISK CUSTOMERS AND BUSINESSES The credit union does not offer foreign correspondent financial institution accounts, does not engage in pouch activities, does not offer special-use accounts, does not offer payable through accounts, or provide U.S. dollar draft services, so no risk