Updated BSA Policy & Procedures Templates

The May 11, 2016, Final Rule on Customer Due Diligence (CDD) requirements created an entirely new section, 31 CFR 1010.230, to address the new beneficial owner rules. One of the provisions is that covered financial institutions are required to establish and maintain written procedures that are reasonably designed to identify and verify beneficial owners of legal entity customers and to include such procedures in their AML Compliance Program.

The Final Rule also amended the current Anti-Money Laundering (AML) Program Requirements, set forth in 31 CFR 1020.210, to “explicitly” include risk-based procedures for conducting ongoing customer due diligence, to include understanding the nature and purpose of customer relationships for the purpose of developing a customer risk profile. This amendment essentially creates a “fifth pillar” of BSA/AML compliance and makes it official that today’s existing CDD regulatory expectations/guidelines are now REQUIRED.

In plain English, this means you need to amend your Bank Secrecy Act (BSA) Policy and update your written BSA Procedures. Do not fear; we are here to help. We have made the required updates to our sample BSA Policy and BSA Procedures templates. You can find them on the Free Downloads page of our website.

 

Want to find out more about our BSA online training? Click to learn more. 

Published
2016/12/30
Deb Irving
David Dickinson

David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

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