AML 2013

• Document No.

• Audit Title

• Client / Site

• Conducted on

  Date

• Prepared by

• Location
  Address

• Personnel

Money Order Log

• 1. Has the money order log been fully completed for all cash transactions of $3,000 or more?

  Yes

  No

  N/A

• 2. Are money Oder daily close out reports reviewed daily by bookkeeper/FEC? (signed & dated; verify multiple transactions totaling $3,000 or more are on close out report and money order log)

  Yes

  No

  N/A

ID Requirements

• 3. Does associate know what qualifies as primary / secondary ID? (primary -government issued, photo,valid expiration / secondary - s.s. number, passport, passport card, alien ID)

  Yes

  No

  N/A

• 4. Does associate know when to prompt for ID for money order? (any transaction of $3,000 or more)

  Yes

  No

  N/A

• 5. Does associate know when to prompt for ID for money transfers? (primary $1,000, secondary $3,000)

  Yes

  No

  N/A

Training

• 6. Review ACT host report, convenience university or training records for updated list of associates who handle money transactions. Is training up to date? (including new and/or transferred associates)

  Yes

  No

  N/A

SAIF and CTR

• 7. Does associate know when to file a SAIF? (suspicious and $2,000)

  Yes

  No

  N/A

• 8. Does associate know when to file a CTR? (cash transaction that exceeds $10,000 in a single day)

  Yes

  No

  N/A

• 9. Does associate know where to send a SAIF or CTR? (fax: GO AML Team (513-246-3878) or email CorpAMLTeam@kroger.com)

  Yes

  No

  N/A

• 10. Does associate how how long they have to send the SAIF / CTR to Corp AML? (48 hours or less)

  Yes

  No

  N/A

Suspicious Activity / Red Flags

• 11. If a customer lowers the dollar amount when told they need to provide an ID, what would the associate do? (should include 1 of the following - refuse the transaction, if sent file a SAIF, call WU hotline to stop transaction, contact appropriate division personnel if necessary)

  Yes

  No

  N/A

• 12. If a customer was not familiar with who they were sending money to, what would the associate do? ( should include 1 of the. Following - ask the customer questions about the transactions and try to explain that this might be a scam, refuse the transaction, if sent then same as question above)

  Yes

  No

  N/A

Compliance

• 13. Is the store using current SAIF or CTR form?

  Yes

  No

  N/A

• 14. Is the current Kroger Anti-Money Laundering Compliance Policy available?

  Yes

  No

  N/A

• 15. Does associate ow who to contact with AML questions? (DCO, corp AML team, FinCEN web site, Barneyweb, FEM/FEC, ect.)

  Yes

  No

  N/A

• 16. Review records and confirm that the store is maintaining records? (6 months for WU send/receive forms and 5 years for all other)

  Yes

  No

  N/A

Western Union

• 17. Select a sample of 15 WU send/receive forms. Are all receipts signed by the customer?

  Yes

  No

  N/A

• 18. How would associate handle a call from a WU representative wanting to do a test transaction? (associate should not complete any transactions over the phone. The associate should hang up the phone, notify store manager, DCO, WU fraud hotline, and Corp AML Team)

  Yes

  No

  N/A