BSA/AML Examiner Training Series 2

BANK SECRECY ACT COMPLIANCE PROGRAM - 12 CFR Part 208.63 Reg H

Code

Failure to develop or implement adequate BSA Compliance Program Section 208.63(a) is issued to assure that all state member banks establish and maintain procedures reasonably designed to assure and monitor their compliance with the provisions of the Bank Secrecy Act (31 U.S.C. 5311, et seq. ) and the implementing regulations promulgated thereunder by the Department of Treasury at 31 CFR part 103, requiring recordkeeping and reporting of currency transactions. Failure to have adequate written Board approved BSA Compliance Program Section 208.63(b)(1) requires the compliance program be reduced to writing, approved by the board of directors, and noted in the minutes. Failure to implement a CIP Section 208.63(b)(2) requires a customer identification program to be implemented as part of the BSA compliance program required under this section. Inadequate system of internal controls for BSA compliance Section 208.63(c)(1) Section 326.8(c)(1) requires that the compliance program, provide for a system of internal controls to assure ongoing compliance. Lack of independent testing of BSA compliance Section 208.63(c)(2) requires that the compliance program, provide for a system of independent testing for compliance to be conducted by bank personnel or by an outside party. Failure to designate individual(s) responsible for BSA compliance Section 208.63(c)(3) requires that the compliance program, designate of an individual or individuals responsible for coordinating and monitor day-to-day compliance. Failure to provide adequate BSA training Section 208.63(c)(4) requires that the compliance program, provide for the training of appropriate personnel.

80,000

80,001

80,002

80,003

80,004

80,005

80,006

Revised 5/3/2023

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