We assisted the New York Branch of an international bank to perform independent testing of the Bank Secrecy Act and Anti-Money Laundering and Sanctions (BSA/AML) Program in the Branch. As part of the independent testing we performed an assessment of the pillars of the BSA/AML program and controls covering including reviewing the BSA/AML Program Policies and Procedures and board approvals, program governance and oversight, designation of a qualified individual as the BSA/AML Compliance officer, assessed independence of the BSA/AML function, including adequacy of staffing, definition of roles & responsibilities. We further tested the BSA/AML Training Program, Know Your Customer (KYC) and Customer Identification Programs (CIP) controls, identification and documentation of beneficial ownership, the Customer Due Diligence (CDD) Program, Enhanced Due Diligence (EDD) procedures for high-risk customers. Additionally we verified adherence to record-keeping requirements, appropriate design and configuration of the transaction monitoring and sanctions screening systems, results of the independent model validation performed, reviewed Office of Foreign Assets Control (OFAC) sanctions policies, procedures and filtering/screening process, sanction list updates, customer, transaction screening procedures and controls.

Note: This work was performed prior to joining Stout.

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