In order to meet the independent testing requirements of the BSA, ICS will verify compliance with BSA/AML policies and procedures, and test internal controls designed to prevent money laundering activity. Our procedures will cover all major business lines, products, and locations, and will include testing in the following areas, as applicable:

• BSA/AML policies, procedures, and programs
• Qualifications of designated individual responsible for coordinating and monitoring day-to-day compliance
• Scope, frequency, and documentation of BSA/AML training
• Knowledge and understanding of institution personnel
• Board and senior management oversight
• Prior audit and examination findings and corrective actions
• Customer Identification Program (CIP)
• Customer and enhanced due diligence
• Currency transaction reports
• Correspondence with the IRS or Treasury
• Currency shipments
• Identification of higher-risk activities, customers, and locations
• Suspicious activity detection and reporting
• Purchases and sales of monetary instruments
• Funds transfer activity
• Office of Foreign Asset Control
• Record retention requirements
• Information sharing requirements