GENERAL ANTI-MONEY LAUNDERING PROGRAM REQUIREMENTS

• Delegation of AML Responsibilities by Mutual Fund

INTERNAL COMPLIANCE

• Hiring Practices
• Developing an Institutional Risk Assessment
• Independent Testing of Internal Compliance

REPORTING RESPONSIBILITIES

• BSA Direct E-Filing System
• Currency Transaction Reports
• Exemption Program
• Sales of Monetary Instruments
• Suspicious Activity Reporting
• Reports of Transportation of Currency or Monetary Instruments
• Reports of Foreign Financial Accounts
• IRS Reporting

RECORDKEEPING RESPONSIBILITIES

• Funds Transfer Recordkeeping Requirements
• Funds Transmittal Recordkeeping

CUSTOMER IDENTIFICATION PROGRAM (CIP)

• Customer Information Obtained Prior to Opening Account
• Customer Verification
• Third-Party Performance of CIP Responsibilities

CUSTOMER DUE DILIGENCE PROGRAM (CDD)

• Pre-PATRIOT Act Supervisory Manual Requirements
• Money Services Business Customers

OFFICE OF FOREIGN ASSETS CONTROL COMPLIANCE

BANK SECRECY ACT TRAINING PROGRAM

SPECIFIC ACCOUNTS, TRANSACTIONS AND RELATIONSHIPS

• Nonresident Aliens (NRAs) and Foreign Individuals
• Embassy and Foreign Consulate Accounts
• Correspondent Accounts
• Correspondent Accounts for Foreign Shell Banks
• Private Banking
• Trust and Asset Management Services
• Payable-Through Accounts
• Concentration Accounts
• Accounts Provided to Non-Bank Financial Institutions (NBFIs)
• Relationships With Professional Service Providers
• Relationships With Non-Governmental Organizations and Charities
• International Business Corporations and Investment Companies
• Cash-Intensive Businesses
• E-Banking
• E-Cash
• Privately Owned ATMs
• Brokered Deposits
• Nondeposit Investment Products (NDIPs)
• Insurance Products
• Trade Finance Activities
• Relationships With Countries, Entities, and Individuals as to Which Special Measures
• Have Been Issued
• Holding Companies
• Parallel Banking Relationships
• Overseas Branches and Offices
• Pouch Activities

INFORMATION SHARING WITH GOVERNMENT AGENCIES

NATIONAL SECURITY LETTERS

DEFENSE DEPARTMENT AUTHORITY TO OBTAIN INFORMATION

INFORMATION SHARING WITH OTHER FINANCIAL INSTITUTIONS

PREPARING FOR EXAMINERS

Banks have a long history of regulation by the Bank Secrecy Act and related regulations, and as a result the checklist for banks at 170 pages and growing is the longest in the series provided here. The reporting and recordkeeping responsibilities for banks have been evolving for decades and there is a great deal of specificity in much of what is required of banks and their employees. Consequently, staff devoted to compliance efforts should be highly trained and should frequently review the requirements for all sections of the institution.

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