Board must designate a qualified individual to serve as BSA Officer
Rain
N/A
BSA
Risk Assessment
RA
Assessment of financial crimes risk, including AML/CFT, fraud and sanctions risks
Rain
Partner
BSA
Customer Identification Program (CIP)
CIP
Collection and verification of key identity elements
Rain
N/A
BSA
Customer Due Diligence (CDD)
CDD
Collection and analysis of additional customer data elements to create customer profile
Rain
N/A
BSA
Customer Risk Rating
CRR
Methodology for measuring AML/CFT risks associated with customer
Rain
Partner
BSA
Enhanced Due Diligence (EDD)
EDD
Collection and analysis of additional customer data elements for high risk clients
Rain
N/A
BSA
PEP Screening
PEP
Screening for customers that hold high political positions
Rain
N/A
BSA
Adverse Media Screening
AM
Screening for other risk indicators including convictions for financial crimes
Rain
N/A
BSA
Risk Acceptance
RA
Defining and making decisions on which customer risks are acceptable and which are not permitted
Rain
Partner
BSA
Transaction Monitoring
TM
Management of customer transactions including design and implementation of program. Includes rule creation, execution, alert disposition, case investigation.
Rain
N/A
BSA
Suspicious Activity Reporting (SAR)
SAR
Reporting of potentially suspicious activities for investigation and possible reporting
Rain
N/A
BSA
Unusual Activity Referrals (UARs)
UAR
Partner
N/A
BSA
Request for Information
RFI
Communicating to customer request for information to be used in fraud mitigation, dispute resolution, and suspicious activity investigations
Partner
N/A
BSA
Ongoing Suspicious Activity Reporting
O-SAR
Submission of report to relevant authorities regarding ongoing suspicious customer activity.
Rain
N/A
BSA
Currency Transaction Reports (CTR)
CTR
Rain
N/A
BSA
Periodic Customer Review
PCR
Rain
N/A
BSA
314a Searches
314a
Rain
N/A
BSA
314b Information Sharing
314b
Rain
N/A
BSA
BSA Training
Training
General and specialized, role-based training of staff in the BSA and implementing regulations including sanctions compliance
Rain
Partner
Sanctions
Sanctions Screening
OFAC-S
Rain
N/A
Sanctions
Blocking/Rejection Actions
OFAC-B
Rain
N/A
Sanctions
Freezing Actions
OFAC-F
Rain
N/A
Sanctions
Sanctions Reporting
OFAC-R
Rain
N/A
Fraud
Customer Onboarding
Fraud-O
Management of fraud screening and rules during onboarding
Rain
Partner
Fraud
Card Transaction Monitoring
Fraud-M
Management of fraud screening and rules for transactions
Rain
Partner
Card Network Rules
PCI DSS
PCI
Requirements for network security, encryption, access controls, and regular security testing
Rain
Partner
Card Network Rules
Geographic Permissions/Prohibitions
PROH-G
Management of geographic permissions for card issuance.
Rain
Partner
Card Network Rules
Load Limits
LL
Limits on debit and prepaid credentials on how much money can be added into the account.
Rain
Partner
Card Network Rules
Velocity Controls
VC
Fraud prevention mechanisms that monitor the frequency, volume, and patterns of transactions over a specific time period.
Rain
Partner
Card Network Rules
Chargeback Rules
Chargebacks
Chargeback rules after customer tries to resolve a dispute with a merchant.
Partner
Rain
Complaints
Complaints
Complaints
Receipt and proper processing and resolution of complaints
Partner
N/A
GLBA
Privacy Notices
GLBA
Provision of privacy notices
Partner
N/A
Vendor Management
Third Party Relationship Management
TPRM
Management of third party vendors
Rain
N/A
Licensing
Licensing
LIC
Management of required licenses to operate
Rain
Partner
State Level Regulation
Data Breach Laws
DB
Advisement of data breaches
Rain
N/A
Marketing
Customer Marketing
Marketing
Partner
Rain
Customer Support
Customer Onboarding
Onboarding UI
Application user interface for customer onboarding and communication
Partner
N/A
Customer Support
Customer User Interface
UI
Application user interface for customers to see balances, transactions, statements, and communication
Partner
N/A
Customer Support
Customer Support
Support
Acts as first-line contact for end-user support and communication
Partner
N/A
All
Compliance Testing
CT
Periodic independent testing of relevant controls and functions (i.e. program Audit)
Rain
N/A
All
Compliance Oversight
CO
Periodic testing of partner controls and functions
Rain
Partner
Partner-Managed Compliance Requirements
Compliance Area
Requirement
Short Name
Description
1st Responsible Party
2nd Responsible Party
BSA
Board-Appointed BSA Officer
DQI
Board must designate a qualified individual to serve as BSA Officer
Partner
N/A
BSA
Risk Assessment
RA
Assessment of financial crimes risk, including AML/CFT, fraud and sanctions risks
Partner
N/A
BSA
Customer Identification Program (CIP)
CIP
Collection and verification of key identity elements
Partner
N/A
BSA
Customer Due Diligence (CDD)
CDD
Collection and analysis of additional customer data elements to create customer profile
Partner
N/A
BSA
Customer Risk Rating
CRR
Methodology for measuring AML/CFT risks associated with customer
Partner
N/A
BSA
Enhanced Due Diligence (EDD)
EDD
Collection and analysis of additional customer data elements for high risk clients
Partner
N/A
BSA
PEP Screening
PEP
Screening for customers that hold high political positions
Partner
N/A
BSA
Adverse Media Screening
AM
Screening for other risk indicators including convictions for financial crimes
Partner
N/A
BSA
Risk Acceptance
RA
Defining and making decisions on which customer risks are acceptable and which are not permitted
Partner
N/A
BSA
Transaction Monitoring
TM
Management of customer transactions including design and implementation of program. Includes rule creation, execution, alert disposition, case investigation.
Partner
Rain
BSA
Suspicious Activity Reporting (SAR)
SAR
Submission of report to relevant authorities regarding potentially suspicious behavior of customers.
Rain
N/A
BSA
Unusual Activity Referrals (UARs)
UAR
Reporting of potentially suspicious activities for investigation and possible reporting
Partner
N/A
BSA
Request for Information
RFI
Communicating to customer request for information to be used in fraud mitigation, dispute resolution, and suspicious activity investigations
Partner
Rain
BSA
Ongoing Suspicious Activity Reporting
O-SAR
Submission of report to relevant authorities regarding ongoing suspicious customer activity.
Rain
N/A
BSA
Currency Transaction Reports (CTR)
CTR
N/A
N/A
BSA
Periodic Customer Review
PCR
Partner
N/A
BSA
314a Searches
314a
N/A
N/A
BSA
314b Information Sharing
314b
N/A
N/A
BSA
BSA Training
Training
General and specialized, role-based training of staff in the BSA and implementing regulations including sanctions compliance
Partner
Rain
Sanctions
Sanctions Screening
OFAC-S
Partner
Rain
Sanctions
Rejection Actions
OFAC-B
Partner
Rain
Sanctions
Blocking/Freezing Actions
OFAC-F
Partner
Rain
Sanctions
Sanctions Reporting
OFAC-R
Partner
Rain
Fraud
Customer Onboarding
Fraud-O
Management of fraud screening and rules during onboarding
Partner
Fraud
Card Transaction Monitoring
Fraud-M
Management of fraud screening and rules for transactions
Partner
Rain
Card Network Rules
PCI DSS
PCI
Requirements for network security, encryption, access controls, and regular security testing
Rain
Partner
Card Network Rules
Geographic Permissions/Prohibitions
PROH-G
Management of geographic permissions for card issuance.
Rain
Partner
Card Network Rules
Load Limits
LL
Limits on debit and prepaid credentials on how much money can be added into the account.
Rain
Partner
Card Network Rules
Velocity Controls
VC
Fraud prevention mechanisms that monitor the frequency, volume, and patterns of transactions over a specific time period.
Rain
Partner
Card Network Rules
Chargeback Rules
Chargebacks
Chargeback rules after customer tries to resolve a dispute with a merchant.
Partner
Rain
Complaints
Complaints
Complaints
Receipt and proper processing and resolution of complaints
Partner
Rain
Vendor Management
Third Party Relationship Management
TPRM
Management of third party vendors
Partner
N/A
Licensing
Licensing
LIC
Management of required licenses to operate
Rain
Partner
State Level Regulation
Data Breach Laws
DB
Advisement of data breaches
Partner
N/A
Marketing
Customer Marketing
Marketing
Partner
N/A
Customer Support
Customer Onboarding
Onboarding UI
Application user interface for customer onboarding and communication
Partner
N/A
Customer Support
Customer User Interface
UI
Application user interface for customers to see balances, transactions, statements, and communication
Partner
N/A
Customer Support
Customer Support
Support
Acts as first-line contact for end-user support and communication
Partner
N/A
All
Compliance Testing
CT
Periodic independent testing of relevant controls and functions (i.e. program Audit)
Partner
N/A
All
Compliance Oversight
CO
Periodic testing of partner controls and functions