Status of Audit and Examination Points  
USA Bank September 30, 2003
Division
Audit Item
Priority
Type
Report Date
Item #
Status
Start
Est. End
Executive Summary
Response
Risk Management As an annual requirement of the Bank Secrecy Act, the compliance program covering the Bank Secrecy Act and the Customer Identification Program must be approved by the Board of Directors and noted in the minutes. This was not done at the last Board of Directors meeting. At some point during the remainder of the current year this must be minuted.
High
 Compliance
31 Aug 2003
7 		In-process
15 Sept 2003
21 Nov 2003		 The compliance program covering the Bank Secrecy Act and the Customer Identification Program will be approved by the Board of Directors and noted in the minutes at the next annual meeting dated November 17th.
Risk Management

A review of the Office of Foreign Asset Control (OFAC) automated filter used to screen payments (i.e., loans, letters of credit, etc.), in order to ensure that such payments are not made to federally restricted countries and terrorists, etc., noted that this filter was not being updated in a very timely manner. The OFAC list was updated by OFAC on 5/2/03 at 3:40 PM while the Branch did not update its system with the new OFAC information until 5/06/03 at 9:28 AM.

Recommendation

The OFAC updated file should be uploaded to our systems as soon as possible after it is issued in order to ensure that no payments are made that may be related to federally restricted countries and terrorists, etc. as listed on the newest OFAC file.
High
 Compliance
31 Jan 2004
10		 In-process
4 Feb 2004
27 Feb 2004

The Data Security Group will immediately download the latest SDN file issued by OFAC and will be uploaded to our systems upon receipt from the compliance staff. The manager of the payment area will verify that a new addition to the list is verified as being flagged by creating a test payment to that individual.

Additionally, the compliance staff will distribute a compliance-alert to the Data Security Group and the manager of the payment area that will require electronic attestation that the new SDN file has been loaded.
Preparer: John Q. Public - Internal Auditor  
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