Bank Secrecy Act Policy Template Update Details

Product Update Notification - 06/28/10

What's New

Topic 3 - Structure of Accountability. Includes the following subtopics:

Board of Directors

Senior Management

Bank Secrecy Act Officer

Compliance Committee

Topic 4 - Compliance Program and Structure. Includes the following subtopics:

General

Consolidated BSA, AML and OFAC Compliance Program

Foreign Branches and Offices

Parallel Banking

Topic 11 - Information Sharing. Includes the following subtopics:

Information Sharing with Federal Agencies

Information Sharing with Other Financial Institutions

Topic 15 - Private Banking. Includes the following subtopics:

General

Responsibility of the Board of Directors

Risk Management and Mitigation

Due Diligence Program for Non-U.S. Persons

Bearer Shares

Topic 16 - Special Measures.

Topic 17 - Foreign Bank and Financial Accounts Reporting.

Topic 20 - Other Products and Services. Includes the following subtopics:

Correspondent Accounts - Domestic

Correspondent Accounts - Foreign

Bulk Shipments of Currency

U.S. Dollar Drafts and Payable Through Accounts

Pouch Activities

Electronic Banking

Automated Clearing House

Electronic Cash

Third Party Payment Processors

Brokered Deposits

Privately Owned Automated Teller Machines

Non-Deposit Investment Products

Insurance

Concentration Accounts

Lending Activities

Trade Finance Activities

Trust and Asset Management Services

Topic 21 - Other Persons and Entities. Includes the following subtopics:

Non-Resident Aliens and Foreign Individuals

Politically Exposes Persons

Embassy and Foreign Consulate Accounts

Non-Bank Financial Institutions

Money Service Businesses

Professional Service Providers

Non-Governmental Organization and Charities

Business Entities

Cash Intensive Businesses

What's Revised

Topic 2 - Policy Statement. Formerly entitled "Policy, Description, Authority and Scope", the following subtopics were relocated:

Internal Controls - Topic 4 (Compliance Program and Structure) as the "General" subtopic. The entire contents were revised.

Designation of Bank Secrecy Act Officer - Topic 3 (Structure of Accountability). The entire contents were revised.

The following subtopics were deleted:

Currency Reporting Requirements

Report of Crimes and Suspected Crimes

Audit Policy

Anti-Money Laundering Policy

Know Your Customer Policy

Customer Identification Program Policy

Office of Foreign Assets Control Policy

Money Service Businesses

Topic 6 - Risk Management and Assessment. Formerly Topic 4, the entire contents of the "General" subtopic were revised.

The following subtopics were relocated to Topic 4 (Compliance Program and Structure

Enterprise Wide BSA, AML and OFAC Compliance Program - No changes.

Foreign Branches and Offices of U.S. Banks - No changes.

Parallel Banking - No changes.

The following subtopics were relocated to Topic 20 (Other Products and Services

Correspondent Accounts - Now broken out into two subtopics (Domestic and Foreign).

U.S. Dollar Drafts and Payable Through Drafts - No changes.

Pouch Activities - No changes

Electronic Banking - Entire contents were revised.

Automated Clearing House - Entire contents were revised.

Electronic Cash - Entire contents were revised.

Third Party Payment Processors - Entire contents were revised.

Brokered Deposits - Third and final paragraphs were revised.

Privately Owned Automated Teller Machines - No changes.

Non-Deposit Investment Products - No changes.

Insurance - No changes.

Concentration Accounts - No changes.

Lending Activities - No changes.

Trade Finance Activities - Entire contents were revised.

Trust and Asset Management Services - No changes.

The following subtopics are now their own topic:

Funds Transfers - Topic 13 (Funds Transfers and Recordkeeping Requirements) - entire contents were revised.

Sale of Monetary Instruments - Topic 12 (Monetary Instruments) - No changes.

Private Banking - Topic 15 (Private Banking) - Entire contents were revised.

The "Non-Bank Financial Institutions" subtopic was relocated to Topic 21 (Other Persons and Entities) - No changes were made.

More changes can be found on the next page.