Bank Secrecy Act (BSA) Policy – Comprehensive Version

Bank Secrecy Act Policy – Comprehensive Version

This Bank Secrecy Act Policy – Comprehensive Version addresses measures used by a bank, credit union, fintech company, or other type of financial institution to comply with the requirements of the Bank Secrecy Act (BSA), including Anti-Money Laundering (AML), Customer Identification Program (CIP), and Office of Foreign Assets Control (OFAC) requirements.

Table of Contents

• Purpose and Contents – Topic 1
• Policy Statement – Topic 2
• Structure of Accountability – Topic 3
• Compliance Program and Structure – Topic 4
• Definitions – Topic 5
• Risk Management and Assessment – Topic 6
• Customer Identification Program Policy – Topic 7
• Suspicious Activity Reporting – Topic 8
• Currency Transaction Reporting – Topic 9
• Currency Transaction Reporting Exemptions – Topic 10
• Information Sharing – Topic 11
• Monetary Instruments – Topic 12
• Funds Transfers and Recordkeeping Requirements – Topic 13
• Anti-Money Laundering Policy – Topic 14
• Private Banking – Topic 15
• Special Measures – Topic 16
• Foreign Bank and Financial Accounts Reporting – Topic 17
• International Transportation of Currency or Monetary Instruments – Topic 18
• OFAC Policy – Topic 19
• Other Products and Services – Topic 20
• Other Persons and Entities – Topic 21
• Know Your Customer Policy – Topic 22
• Rules for Real Estate Closings and Settlements – Topic 23
• Rules for Investment Advisers – Topic 24
• Audit Policy – Topic 25
• Staff Training – Topic 26
• Penalties – Topic 27
• Retention of Documentation – Topic 28

Includes the following form templates:

• BSA Certification for Beneficial Owners Form (2 pages)
• BSA Checklist for Funds Transfers (1 page)
• BSA Checklist for High Risk Accounts (1 page)
• BSA CIP New Customer Information Sheet (1 page)
• BSA Exemption Form (1 page)
• BSA Monetary Instrument Log Form Template (2 pages)
• BSA Money Services Business Checklist (2 pages)
• BSA Money Services Business Questionnaire (4 pages)
• BSA SAR Incident Report (2 pages)
• BSA Suspicious Activity Report Notices (181 pages)

Recent updates to this product:
04/15/25 Update
FinCEN Alert FIN-2025-Alert001 – FinCEN Alert on Bulk Cash Smuggling and Repatriation by Mexico-Based Transnational Criminal Organizations
FinCEN Advisory FIN-2025-A001 – FinCEN Advisory on the Financing of the Islamic State of Iraq and Syria (ISIS) and its Global Affiliates
04/01/25 Update
FinCEN Interim Final Rule – Beneficial Ownership Information Reporting Requirement Revisions and Deadline Extension
03/03/25 Update
FinCEN Notice FIN-2025-CTA1 – FinCEN Extends Beneficial Ownership Information Reporting Deadline by 30 Days; Announces Intention to Revise Reporting Rule
02/03/25 Update
OFAC Final Rule – Inflation Adjustment of Civil Monetary Penalties
01/02/25 Update
FinCEN Alert FIN-2024-Alert005 – FinCEN Alert on Fraud Schemes Abusing FinCEN’s Name, Insignia, and Authorities for Financial Gain
12/02/24 Update
FinCEN Notice FIN-2024-NTC7 – FBAR Filing Requirement for Certain Financial Professionals: Extended Filing Date Related to FIN-2023-NTC5
FinCEN Alert FIN-2024-Alert004 – FinCEN Alert on Fraud Schemes Involving Deepfake Media Targeting Financial Institutions
11/04/24 Update
FinCEN Final Rule – Update to the Public Utility Exemption Under the Beneficial Ownership Information Reporting Rule
FinCEN Alert FIN-2024-Alert003 – FinCEN Alert to Financial Institutions to Counter Financing of Hizballah and its Terrorist Activities
10/15/24 Update
OFAC Final Rule – Reporting, Procedures and Penalties Regulations
09/16/24 Update
FinCEN Final Rule – Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Reporting Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers
FinCEN File Rule – Anti-Money Laundering Regulations for Residential Real Estate Transfers
OFAC Interim Final Rule – Reporting, Procedures and Penalties
08/01/24 Update
FinCEN Alert FIN-2024-Alert002 – Supplemental Alert:  FinCEN Highlights Additional Red Flags Regarding Financing of Israeli Extremist Settler Violence Against Palestinians in the West Bank
FinCEN Notice FIN-2024-NTC2 – FinCEN, OFAC, and FBI Joint Notice on Timeshare Fraud Associated with Mexico-Based transnational Criminal Organizations
07/15/24 Update
FinCEN Advisory FIN-2024-A002 – Supplemental Advisory on the Procurement of Precursor Chemicals and Manufacturing Equipment Used for the Synthesis of Illicit Fentanyl and Other Synthetic Opioids
06/03/24 Update
FIN-2024-A001 – FinCEN Advisory to Financial Institutions to Counter the Financing of Iran-Backed Terrorist Organizations
OFAC Interim Final Rule – Reporting, Procedures and Penalties Regulations
05/01/24 Update
FIN-2024-NTC1 – FinCEN Notice on the Use of Counterfeit U.S. Passport Cards to Perpetrate Identity Theft and Fraud Schemes at Financial Institutions
03/04/24 Update
FinCEN Final Rule – Beneficial Ownership Information Access and Safeguards
OFAC Final Rule – Inflation Adjustment of Civil Monetary Penalties
02/15/24 Update
FIN-2024-Alert001 – FinCEN Alert on Israeli Extremist Settler Violence Against Palestinians in the West Bank
01/02/24 Update
FinCEN Notice FIN-2023-NTC5 – FBAR Filing Requirement for Certain Financial Professionals: Extended Filing Date Related to Notice 2022-1
12/04/23 Update
FinCEN Final Rule – FinCEN Extends Deadline for Companies Created or Registered in 2024 to File Beneficial Ownership Information Reports
FIN-2023-Alert007 – FinCEN Alert on COVID-19 Employee Retention Credit Fraud
11/15/23 Update
FinCEN Final Rule – FinCEN Finalizes Rule on Use of FinCEN Identifiers in Beneficial Ownership Information Reporting
FinCEN-2023-NTC2 – FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security Announce New Reporting Key Term and Highlight Red Flags Relating to Global Evasion of U.S. Export Controls
11/01/23 Update
FIN-2023-Alert006 – FinCEN Alert to Financial Institutions to Counter Financing to Hamas and its Terrorist Activities
09/18/23 Update
FIN-2023-Alert005 – FinCEN Alert on Prevalent Virtual Currency Investment Scam Commonly Known as Pig Butchering
09/05/23 Update
FinCEN FIN-2023-NTC1 – FinCEN Calls Attention to Payroll Tax Evasion and Workers’ Compensation Fraud in the Construction Sector
08/15/23 Update
FFIEC Announcement 2023-02 – Federal and State Regulators Release Updates to the BSA/AML Examination Manual
06/01/23 Update
FinCEN – Supplement Alert:  FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security Urge Continued Vigilance for Potential Russian Export Control Evasion Attempts
04/17/23 Update
FinCEN – Business Email Compromise in the Real Estate Sector: Threat Pattern and Trend Information, January 2020 to December 2021
03/15/23 Update
FIN-2023-Alert003 – FinCEN Alert on Nationwide Surge in Mail Theft-Related Check Fraud Schemes Targeting the U.S. Mail
02/01/23 Update
FIN-2023-Alert001 – FinCEN Alert on Human Smuggling Along the Southwest Border of the United States
FIN-2023-Alert002 – FinCEN Alert on Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites, Oligarchs, and Their Proxies
02/01/23 Update
OFAC Final Rule – Inflation Adjustment of Civil Monetary Penalties
01/03/23 Update
U.S. Treasury Recent Action – Publication of Illicit Drug Trade Sanctions Regulations
12/15/22 Update
FinCEN Notice 2022-1 – FBAR Filing Requirement for Certain Financial Professionals
10/17/22 Update
FinCEN Final Rule – Beneficial Ownership Information Reporting Requirements
OFAC Communique – Sanctions Compliance Guidance for Instant Payment Systems
10/03/22 Update
OFAC – Amendment to the Cyber-Related Sanctions Regulations and Associated Administrative List Updates
07/18/22 Update
FIN-2022-Alert003 – FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security Urge Increased Vigilance for Potential Russian and Belarusian Export Control Evasion Attempts
07/05/22 Update
FinCEN – Statement on Bank Secrecy Act Due Diligence for Independent ATM Owners or Operators
FinCEN Advisory FIN-2022-A002 – Advisory on Elder Financial Exploitation

This Bank Secrecy Act Policy – Comprehensive Version (approximately 311 pages) is available to purchase from BankPolicies.com in Microsoft® Word format.

Product Update Protection Plan

Ensure your purchase from BankPolicies.com remains current by adding a Product Update Protection Plan to your shopping cart.  You’ll automatically receive an updated version via e-mail every time it’s revised, within one year from the last date of purchase.

We’re Here to Help

BankPolicies.com provides digital access to over 500 professional bank policy, job description, and form templates for automatic download.

BankPolicies.com keeps your financial institution up to date with the latest bank policy standards and industry best practices.  Purchase your bank policies from us today and rest easy knowing you have the right team helping you and your organization stay compliant.  We are ready to earn your business for all of your bank policy needs.  Order your policy template today.