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
- BSA Checklist for Funds Transfers
- BSA Checklist for High Risk Accounts
- BSA CIP New Customer Information Sheet
- BSA Exemption Form
- BSA Monetary Instrument Log Form Template
- BSA Money Services Business Checklist
- BSA Money Services Business Questionnaire
- BSA SAR Incident Report
- BSA Suspicious Activity Report Notices
Recent updates to this product:
10/15/26 Update
OFAC Final Rule
09/14/26 Update
Joint Release – Joint Statement on Suspicious Activity Report Confidentiality Considerations Regarding Communications with Customers
08/17/26 Update
FinCEN Final Rule – Beneficial Ownership Information Reporting Requirement Revision
08/03/26 Update
OFAC Final Rule – Updating Website and Contact Information, and Authorizations for Payments for Legal Services
05/04/26 Update
FDIC FIL-16-2026 – Agencies Revise the Interagency Model Risk Management Guidance and OCC Bulletin 2026-13 – Model Risk Management; Revised Guidance
03/16/26 Update
FFIEC – Updated Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual
03/02/26 Update
FinCEN Ruling FIN-2026-R001 – Exceptive Relief from Requirement to Identify and Verify Beneficial Owners at Each Account Opening
12/15/25 Update
FinCEN Notice FIN-2025-NTC3 – FBAR Filing Requirement for Certain Financial Professionals: Extended Filing Date Related to FIN-2024-NTC7
11/17/25 Update
Nacha Release – Definition and IAT Entries
Nacha Release – Registration of IAT Contacts in the ACH Contact Registry
Nacha Release – International ACH Transactions(IAT)
Nacha Release – New Return Reason Code for Sanctions Compliance Obligations
09/15/25 Update
FinCEN Guidance – Cross-Border Information Sharing by Financial Institutions and SAR Confidentiality
08/18/25 Update
FinCEN – Exemptive Relief Order to Delay the Effective Date of the Investment Adviser Rule
07/15/25 Update
FinCEN Press Release – FinCEN Permits Banks to Use Alternative Method for Obtaining TIN Information
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
11/04/24 Update
FinCEN Final Rule – Update to the Public Utility Exemption Under the Beneficial Ownership Information Reporting Rule
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
06/03/24 Update
OFAC Interim Final Rule – Reporting, Procedures and Penalties Regulations
03/04/24 Update
FinCEN Final Rule – Beneficial Ownership Information Access and Safeguards
OFAC Final Rule – Inflation Adjustment of Civil Monetary Penalties
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
This Bank Secrecy Act Policy – Comprehensive Version (approximately 319 pages) is available to purchase from BankPolicies.com in Microsoft® Word format.
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