Product Updates December 2016 is providing you with these product updates as a courtesy to all of our clients. If you have any questions, please contact us.

New Policy Template

Foreign Correspondent Banking Policy Template

This new product was developed in response to client requests and OCC Bulletin 2016-32 that describes corporate governance best practices for banks when conducting periodic evaluation of the risks related to correspondent accounts for foreign financial institutions (foreign correspondent accounts).  In addition, the guidance reiterates supervisory expectation that, in connection with implementing the requirement that banks have established policies and procedures for conducting risk assessments for foreign correspondent accounts, banks should periodically evaluate and reassess this risk (risk reevaluation) as part of their ongoing risk management and due diligence practices.

Revised Policy Templates

The update to these products is in response to the FinCEN’s final rule entitled “Technical Amendments to Various Bank Secrecy Act Regulations“ dated 11/04/16 that updates various sections of the regulations implementing the Bank Secrecy Act (“BSA”) by removing or replacing outdated references to obsolete BSA forms, removing references to outdated recordkeeping storage media, and replacing several other outdated terms and references.

The update to these products is in response to the FinCEN’s Advisory FIN-2016-A005 entitled “Advisory to Financial Institutions on Cyber-Events and Cyber-Enabled Crime“ dated 10/25/16 that highlights how BSA reporting helps U.S. authorities combat cyber-events and cyber-enabled crime by:

  • Reporting cyber-enabled crime and cyber-events through Suspicious Activity Reports (SARs);
  • Including relevant and available cyber-related information (e.g., Internet Protocol (IP) addresses with timestamps, virtual-wallet information, device identifiers) in SARs;
  • Collaborating between BSA/Anti-Money Laundering (AML) units and in-house cybersecurity units to identify suspicious activity; and
  • Sharing information, including cyber-related information, among financial institutions to guard against and report money laundering, terrorism financing, and cyber-enabled crime.

Regulation D Policy Template

This product was revised in response to the Federal Reserve’s Press Release dated 10/27/16 that announced the annual indexing of two amounts used in determining reserve requirements of depository institutions. These amounts are the reserve requirement exemption amount and the low reserve tranche.