Bank Secrecy Act Policy – Comprehensive Version
This Bank Secrecy Act Policy Template – Comprehensive Version addresses measures used by a bank, credit union, 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
- Audit Policy – Topic 23
- Staff Training – Topic 24
- Penalties – Topic 25
- Retention of Documentation – Topic 26
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 (132 pages)
Recent updates to this product:
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
05/02/22 Update
FinCEN Advisory FIN-2022-A001 – Advisory on Kleptocracy and Foreign Public Corruption
04/04/22 Update
FIN-2022-Alert002 – FinCEN Alert on Real Estate, Luxury Goods, and Other High-Value Assets Involving Russian Elites, Oligarchs, and their Family Members
OCC New Release 2022-23 – OCC Issues Final Rule Addressing Authority for Exemptions to Suspicious Activity Report Requirements
03/15/22 Update
FIN-2022-A001 – FinCEN Advises Increased Vigilance for potential Russian Sanctions Evasion Attempts
12/15/21 Update
FFIEC Press Release – Federal and State Regulators Release Updates to BSA/AML Examination Manual
FinCEN Notice 2021-1 – FBAR Filing Requirement for Certain Financial Professionals
12/01/21 Update
FIN-2021-A004 – Advisory on Ransomware and the Use of the Financial System to Facilitate Ransom Payments
FIN-2021-NTC4 – FinCEN Calls Attention to Environmental Crimes and Related Financial Activity
10/04/21 Update
FIN-2021-NTC3 – FinCEN Calls Attention to Online Child Sexual Exploitation Crimes
07/01/21 Update
FFIEC – Federal and State Regulators Release Updates to the BSA/AML Examination Manual
05/01/21 Update
Joint Release – Interagency Statement on Model Risk Management for Bank Systems Supporting Bank Secrecy Act/Anti-Money laundering Compliance
04/01/21 Update
OFAC Final Rule – Inflation Adjustment of Civil Monetary Penalties
OFAC Final Rule – Adjustment of Applicable Schedule Amount
03/15/21 Update
FFIEC – Revised FFIEC BSA/AML Examination Manual
FinCEN – Advisory on Financial Crimes Targeting COVID-19 Economic Impact Payments
FinCEN – FinCEN Informs Financial Institutions of Efforts Related to Trade in Antiquities and Art
02/16/21 Update
FIN-2021-A001 – Advisory on COVID-19 Health Insurance- and Health Care-Related Fraud
01/04/21 Update
FIN-2020-NTC4 – FinCEN Asks Financial Institutions to Stay Alert to COVID-19 Vaccine-Related Scams and Cyberattacks
FinCEN Notice 2020-1 – Report for Foreign Bank and Financial Accounts (FBAR)
This Bank Secrecy Act Policy Template – Comprehensive Version (approximately 285 pages) is available to purchase from BankPolicies.com in Microsoft® Word format.
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