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 (117 pages)
Recent updates to this product:
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)
12/01/20 Update
Joint Release – FinCEN and Federal Banking Agencies Clarify BSA Due Diligence Expectations for Charities and Non-Profit Customers
11/02/20 Update
FIN-2020-A007 – Advisory on Unemployment Insurance Fraud During the Coronavirus Disease 2019 (COVID-19) Pandemic
FIN-2020-A008 – Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity
10/15/20 Update
FIN-2020-A006 – Advisory on Ransomware and the Use of the Financial System to Facilitate Ransom Payments
Joint Release – Federal Banking Agencies and FinCEN Announce Exemption from Customer Identification Program Requirements for Premium Finance Loans
OFAC – Ransomware Advisory
10/01/20 Update
FinCEN Final Rule: Financial Crimes Enforcement Network; Customer Identification Programs, Anti-Money Laundering Programs, and Beneficial Ownership Requirements for Banks Lacking a Federal Functioning Regulator
09/14/20 Update
OFAC Interim Final Rule – Inflation Adjustment of Civil Monetary Penalties Related to Reporting and Recordkeeping
09/01/20 Update
Joint Press Release – Joint Statement on Bank Secrecy Act Due Diligence Requirements for Customers Who May Be Considered Politically Exposes Persons
08/17/20 Update
FIN-2020-Alert001 – FinCEN Alerts Financial Institutions to Convertible Virtual Currency Scam Involving Twitter
FIN-2020-A005 – Advisory on Cybercrime and Cyber-Enabled Crime Exploiting the Coronavirus Disease 2019 (COVID-19) Pandemic
OFAC – Final Rule
07/15/20 Update
FinCEN Guidance Regarding Due Diligence Requirements Under the Bank Secrecy Act for Hemp-Related Business Customers
FIN-2020-A003 – Advisory on Imposter Scams and Money Mule Schemes Related to Coronavirus Disease 2019 (COVID-19)
This Bank Secrecy Act Policy Template – Comprehensive Version (approximately 280 pages) is available to purchase from BankPolicies.com in Microsoft® Word format.
Want to ensure your purchase from BankPolicies.com remains current? Add a Product Update Protection Plan to your shopping cart to ensure that you will automatically receive an updated version every time it is revised via e-mail within one year from the last date of purchase. This timely and cost-effective solution ensures that you stay on top of federal regulatory changes and industry recommended best practices.
When updates are made you will receive detailed information regarding why the product was updated and what has changed within the product in our Product Update Notification e-mail correspondence. This enables you to make an informed decision on whether to make any changes to the policy or procedure you implemented for your financial institution from the revised template.
BankPolicies.com provides your financial institution with the best bank policy template products available in the industry. You will always be up to date with the latest changes to bank policies and never have to worry about being out of compliance with the various laws, rules and regulations issued by the Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Reserve, Office of the Comptroller of the Currency (OCC), or other federal regulatory bodies that may apply to your organization.
Our dedicated staff of career banking industry professionals are ready to keep 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 look forward to earning your business for all of your bank policy needs.
