Overview

Responsibilities:

Compliance

  • Establish and maintain the compliance program as described in compliance policies and procedures.
  • Monitor changes and new regulatory requirements affecting the Bank and communicating those requirements to the Chief Compliance Officer of Head Office through Compliance & Legal Department, Management, and the staff.
  • Update the compliance program on a timely basis when applicable federal, state and home country laws regulations impact the Bank’s operations.
  • Carry out compliance monitoring in accordance with the established compliance manual.
  • Respond to audit findings related to compliance matters, as requested.
  • Ensure timely reporting to senior management and the Chief Compliance Officer of Head Office of significant risk issues, and serious lapses or breaches of laws and regulations applicable to the Bank.
  • Perform at least annually an assessment of the Bank’s compliance related risks.
  • Assure that compliance and regulatory training is given as mandated by law such as Bank Secrecy Act, U.S. Patriot Act and Gramm-Leach-Bliley Act.
  • Semi-annual Compliance Report to the Chief Compliance Officer of Head Office.
  • Quarterly EPS Compliance Report to Head Office.
  • Conduct Quarterly Compliance Self-Assessment Training and Quiz as required by Head Office
  • Review OFAC, SAR, FinCEN314a escalated alerts, case investigation & filing, Review new account CIP & risk profile and annual update, Review monthly respective department monitoring reports.

 

Compliance Dept Schedule Routines (In-charge and Back up)

Daily

  • Check OFAC SDN Changes
  • Bridger Insight incoming messages OFAC alerts review
  • Bridger Insight outgoing messages OFAC alerts review
  • Monitor changes and new regulatory requirements affecting the Bank

On Demand

  • FGBS OFAC update –Bridger Insight OFAC update—FinCEN 314(a) request download
  • Bridger Insight FinCEN 314(a) update —-FinCEN 314(a) request reply
  • OFAC investigation
  • Review new account CIP & risk profile
  • Court subpoenas investigation & reply
  • Review letter from Federal Reserve Bank, Department of Financial Services

Monthly

  • Review Asset pledge report
  • Review Fund Transfer EDD Log reports & EDD subject conclusions monthly
  • Review MT202 activities monitoring report
  • Review Vostro account activities
  • Review Time Deposit monitoring report
  • Review Commercial Loan monitoring report
  • Review Correspondent Account monitoring report
  • SAR monitoring & reporting (branch wide by respective dept staff & manager)
  • SAR log (SAR decision meetings and documentation)
  • SAR filing

Quarterly

  • Review Fund transfer activities monitoring report
  • Semi-Annually
  • Compliance Report
  • Compliance training (in General Meetings as needed)

Annually

  • Review Abandoned property report (early August)
  • Monitor mailing of Notice of Privacy of Consumer Financial Information Policy
  • Review Time Deposit risk profile
  • Review Commercial Loan risk profile
  • Review Correspondent bank, Due-To bank risk profile
  • Conduct Compliance training & quiz
  • BSA risk assessment —OFAC risk assessment
  • Compliance review
  • Policy and procedure revision
  • Monitor update of W-8 BEN (every 3 years)