BSA Policy Update

Bank Secrecy Act Policy Template Update 09/12/06 Detail

Topic 2 - Policy Description, Authority and Scope. The subtopic "Internal Controls" was added as a policy statement reference.

An additional statement regarding the necessary qualifications of a BSA/OFAC Officer was added under the "Designation of Bank Secrecy Act Officer" subtopic.

A new subtopic "Office of Foreign Assets Control Policy" was added to reference a financial institution's OFAC Policy.

Topic 3 - Definitions. Formerly Topic 4, no changes.

Topic 4 - Risk Management and Assessment. Formerly Topic 4, the following subtopics were completely revised to include greater details:

General

Customer Base

Geographic Locations

Product and Services Offered

The following subtopics were added at the request of numerous clients to provide detailed examples of specific risk assessment guidelines:

OFAC Risk Assessment Program

Parallel Banking

Correspondent Accounts

U.S. Dollar Drafts and Payable Through Accounts

Pouch Activities

Electronic Banking

Wire Transfers

Automated Clearing House Transactions

Electronic Cash

Third Party Payment Processors

Sale of Monetary Instruments

Brokered Deposits

Privately Owned Automated Teller Machines

Non-Deposit Investment Products

Insurance

Concentration Accounts

Lending Activities

Trade Finance Activities

Private Banking

Trust and Asset Management Services

Topic 5 - Currency Transaction Reporting. Formerly Topic 9, a new subtopic "Currency Transaction Reports" was added to reference the ability of a financial institution's host computer system to generate reports for tracking and monitoring purposes.

Topic 6 - Certification of CTR. Formerly Topic 10, no changes.

Topic 7 - Exemptions. Formerly Topic 6, The following subtopics were added to provide greater detail for each subject:

Filing Requirements

Ineligible Businesses

Safe Harbor

Effect on Other Regulatory Requirements

Topic 8 - New Exemption. Formerly Topic 7, an IRS required filing time was added to this topic.

Topic 9 - Certification of Exemption List. Formerly Topic 8, no changes.

Topic 10 - Requests for Information. Formerly Topic 11, no changes.

Topic 11 - Suspicious Transactions. Formerly Topic 12, no changes.

Topic 12 - Currency and Foreign Transaction Reporting. Formerly Topic 13, three new paragraphs were added to the topic to provided greater detail of the requirements.

Topic 13 - Identification for Elderly or Disabled People. Formerly Topic 14, no changes.

Topic 14 - Monetary Log Guidelines. Formerly Topic 15, the minimum amount of information to be retained was revised to exactly mirror that contained in the guidance under the "General" subtopic.

Topic 15 - Certification of Monetary Logs. Formerly Topic 16, no changes.

Topic 16 - Funds Transfer System. Formerly Topic 17, the "General" subtopic was revised to mirror guidance requirements.

The following subtopics were added to provide greater detail:

Additional Records for Non-Established Customers

Retrievability

Travel Rule Requirement

Responsibilities of Intermediary Institutions

Responsibilities of Beneficiary Banks

Abbreviations and Addresses

Customer Address

Topic 17 - Report of Crime and Suspected Crimes. Formerly Topic 18, the "Filing Requirements" and "Confidentiality" items under the "Suspicious Activity Report" subtopic were revised to mirror regulatory guidance.

The following subtopics were added to provide greater detail:

Safe Harbor from Civil Liability

Automated Monitoring System

Law Enforcement Inquiries and Requests

National Security Letters

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