Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual

Private Banking Due Diligence Program (Non-U.S. Persons) — Overview

Special Procedures When Due Diligence Cannot Be Performed A bank’s due diligence policies, procedures, and controls established pursuant to 31 CFR 1010.620(a) must include special procedures when appropriate due diligence cannot be performed. These special procedures must include when the bank should:

• Refuse to open the account. • Suspend transaction activity. • File a SAR. • Close the account.

FFIEC BSA/AML Examination Manual

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