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BSA

BSA. Amy Magnus Amagnus@ANDeringer.com. Broker Self Assessment What Did the Brokers Want?. Taken out of the Pool of Audit National Treatment Capping of Penalties and Beneficial Mitigation Prior Disclosure Benefits under 19 USC 1641 Voluntary Program

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BSA

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  1. BSA Amy Magnus Amagnus@ANDeringer.com

  2. Broker Self AssessmentWhat Did the Brokers Want? • Taken out of the Pool of Audit • National Treatment • Capping of Penalties and Beneficial Mitigation • Prior Disclosure Benefits under 19 USC 1641 • Voluntary Program • Preferential Treatment for Post-Summary Submissions • Expanded National Permit Privileges

  3. Broker Self AssessmentWhat Did CBP Want? • Partnership Program Similar to ISA • A Better Understanding of how Brokers Conduct Business • How to Apply the “Controls” to Brokerage • Finding the Commonality Among Brokers • Assurances of Compliance

  4. What Did CBP Get? • 4 Completely Different Participants • Time Consuming Front End Preparation • RAD Review of BSA Profile • 3 Years of Data Review (BEAR and other internal Data) • Seemingly No Commonality

  5. The 5 Standards • Control Environment • Demonstrate management’s commitment to compliance • Risk Assessment • Identify and analyze relevant risk and develop internal goals to manage risk • Control Activities • Develop, implement and modify formal policies and procedures to ensure that management's goals and objectives are met • Information and Communication • Ensure employees receive appropriate training and guidance • Monitoring • Conduct periodic process reviews to assess the performance quality of the internal controls

  6. What Did CBP Do? • RAD Team did an On-Site Visit – 3 Days • Tried to Focus on the 5 Areas of Control • Reviewed 4 Entries Not Randomly Selected • Asked to See an Entry Keyed • Asked to See “New Client” Materials • Asked to See HR Manual • Asked to See Internal News Letters

  7. Did BSA Hit the Mark? • Can CBP identify brokers who have higher standards? • How can CBP translate the hours devoted to the program into facilitating transactions? • Does laying the ISA template over BSA work? • Will a rewrite of Part 111 help?

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