Bank Secrecy Act Policy Update Details

Product Update Notification - 09/27/07

Bank Secrecy Act Policy Template Update Details

What's New

The BSA Monetary Instrument Log Form Template is now included in the purchase price of the product.

What's Revised

Topic 3 - Definitions. The "Covered Financial Institution" definition was deleted and replaced with "Financial Institution." In addition:

The following definitions were added:

Foreign Shell Bank - Regulated Affiliate

Payable Through Account

Publicly Traded Foreign Bank

The following definitions were revised:

Foreign Financial Institution

Foreign Shell Bank

Topic 4 - Risk Management and Assessment. The following subtopics were added:

Enterprise Wide BSA, AML and OFAC Compliance Program

Foreign Branches and Offices of U.S. Banks

Non-Bank Financial Institutions

The following subtopics were revised:

Quantity of Risk Standards

Correspondent Accounts (bullet points 1.-9. and the remaining paragraphs)

Electronic Banking

Funds Transfers (formerly called "Wire Transfers")

Automated Clearing House Transactions (last three paragraphs)

Privately Owned Automated Teller Machines

Trade Finance Activities

Topic 5 - Currency Transaction Reporting. The following subtopics were added:

Structuring

Certification of CTR (formerly Topic 6)

Topic 6 - Currency Transaction Exemptions. Formerly Topic 7 - Exemptions, this topic now includes the following subtopics:

New Exemption Procedures (formerly Topic 8)

Certification of Exemption List (formerly Topic 9)

Topic 7 - Currency and Foreign Transaction Reporting. Formerly Topic 12, the second to the last paragraph was revised to include additional filing guidance.

Topic 8 - Monetary Instrument Log Guidelines. Formerly Topic 14 - Monetary Log Guidelines, this topic now includes the "Certification of Monetary Logs" (formerly Topic 15).

Topic 10 - Suspicious Activity Reporting. Formerly Topic 17 - Report of Crimes and Suspected Crimes, the last full paragraph on page 51 of the current product was revised to provide additional procedures under the "Suspicious Activity Report" subtopic. In addition, a new "Manual Transaction Monitoring" subtopic was added.

Topic 11 - Anti-Money Laundering Policy. Formerly Topic 18, the following subtopics were revised:

Policy Statement

Risk Analysis and Assessment (formerly Risk Analysis)

Foreign and High Risk Correspondent Accounts (added last paragraph)

Business Entities (formerly Shell Companies, Agents and Nominee Incorporation Services)

The following subtopics were added:

Structure of Accountability

Risk Mitigation Strategies

Money Laundering and Terrorist Financing Red Flags

Enhanced Due Diligence for Certain Foreign Banks

Topic 13 - Customer Identification Program Policy. Formerly Topic 20, the following subtopics were revised:

Enhanced Due Diligence Standards for High Risk Customers (bullet point 3.)

Rules for Politically Exposed Persons (first two full paragraphs were added to page 98 of the current product and bullet point 9. was revised)

Topic 14 - OFAC Policy. The following subtopics were revised:

Policy Statement (first three paragraphs and two bullet points)

Prohibited Transactions (only a change in name of subtopic from "Rejecting Transactions")

Automated Clearing House Transactions (first three paragraphs)

Topic 15 - Money Service Business Guidelines. Formerly Topic 22, the following subtopics were revised:

Minimum Bank Secrecy Act Due Diligence Guidelines (first three paragraphs and bullet points 1.-10.)

Due Diligence Guidelines for Higher Risk Customers (bullet points 1.-5. and 1.-7.)

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