Internal Control Questionnaires and Verification Procedures

31 CFR 103, 12 CFR 21.21—Compliance Questionnaire

1. Is form 4789 completed and submitted within 15 days and form 4790 prepared and submitted according to the prescribed timeframes?

2. Has the bank established, in writing and approved by the board of directors, formal operating procedures to ensure compliance with the regulation?

3. Do operating procedures set forth the reporting requirements of the regulation and establish compliance guidelines for large cash transactions and exemptions granted to customers?

4. Does the record retention schedule, at a minimum, include the record retention requirements of the regulation and contain requirements for the maintenance of lists of exempt customers with retail affiliations, and customers from whom taxpayer identification numbers have not been obtained?

5. Has the bank established a program of employee education on the requirements of the regulation?

   1. Are tellers, through an ongoing training program, informed of the reporting requirements for large cash transactions?

   2. Are operations personnel made aware of the current requirements of the regulation and does management periodically reinforce the importance of compliance?

6. Has the bank designated an individual(s) to be responsible for coordinating and monitoring daily compliance with 31 CFR 103?

Previous: 12 CFR 21—Compliance Questionnaire Next: International Division