| Introduction | 2 |
| Scoping and Planning | 12 |
| Risk-Focused BSA/AML Supervision | 14 |
| Developing the BSA/AML Examination Plan | 19 |
| BSA/AML Risk Assessment | 21 |
| Assessing the BSA/AML Compliance Program | 25 |
| BSA/AML Internal Controls | 27 |
| BSA/AML Independent Testing | 29 |
| BSA Compliance Officer | 32 |
| BSA/AML Training | 34 |
| Developing Conclusions and Finalizing the Exam | 36 |
| Assessing Compliance with BSA Regulatory Requirements | 41 |
| Introduction | 41 |
| Customer Identification Program | 42 |
| Customer Due Diligence | 51 |
| Beneficial Ownership Requirements for Legal Entity Customers | 58 |
| Suspicious Activity Reporting | 63 |
| Currency Transaction Reporting | 79 |
| Transactions of Exempt Persons | 84 |
| Information Sharing | 90 |
| Purchase and Sale of Certain Monetary Instruments Recordkeeping | 95 |
| Funds Transfers Recordkeeping | 98 |
| Foreign Correspondent Account Recordkeeping, Reporting and Due Diligence | 104 |
| Private Banking Due Diligence Program (Non-U.S. Persons) | 112 |
| Special Measures | 117 |
| Reports of Foreign Financial Accounts | 121 |
| International Transportation of Currency or Monetary Instruments Reporting | 123 |
| Office of Foreign Assets Control | 126 |
| Program Structures | 136 |
| BSA/AML Compliance Program Structures | 136 |
| Foreign Branches and Offices of U.S. Banks | 142 |
| Parallel Banking | 146 |
| Risks Associated with Money Laundering and Terrorist Financing | 147 |
| Introduction - Customers | 147 |
| Correspondent Accounts (Domestic) | 149 |
| Correspondent Accounts (Foreign) | 151 |
| Bulk Shipments of Currency | 155 |
| U.S. Dollar Drafts | 161 |
| Payable Through Accounts | 162 |
| Pouch Activities | 164 |
| Electronic Banking | 166 |
| Funds Transfers | 170 |
| Automated Clearing House Transactions | 177 |
| Prepaid Access | 185 |
| Third-Party Payment Processors | 191 |
| Purchase and Sale of Monetary Instruments | 195 |
| Brokered Deposits | 196 |
| Independent Automated Teller Machine Owners or Operators | 198 |
| Nondeposit Investment Products | 203 |
| Insurance | 207 |
| Concentration Accounts | 210 |
| Lending Activities | 212 |
| Trade Finance Activites | 213 |
| Private Banking | 218 |
| Trust and Asset Management Services | 223 |
| Nonresident Aliens and Foreign Individuals | 227 |
| Politically Exposed Persons | 229 |
| Embassy, Foreign Consulate, and Foreign Mission Accounts | 233 |
| Non-Bank Financial Institutions | 235 |
| Professional Service Providers | 243 |
| Charities and Nonprofit Organizations | 244 |
| Business Entities (Domestic and Foreign) | 248 |
| Cash-Intensive Businesses | 254 |
| Appendices | 256 |
| Appendix 1 – Beneficial Ownership | 256 |
| Appendix A – BSA Laws and Regulations | 259 |
| Appendix B – BSA/AML Directives | 265 |
| Appendix C – BSA/AML References | 266 |
| Appendix D – Statutory Definition of Financial Institution | 271 |
| Appendix E – International Organizations | 273 |
| Appendix F – Money Laundering and Terrorist Financing Red Flags | 274 |
| Appendix G – Structuring | 284 |
| Appendix H – Request Letter Items (Core and Expanded) | 286 |
| Appendix I – Risk Assessment Link to the BSA/AML Compliance Program | 304 |
| Appendix J – Quantity of Risk Matrix | 305 |
| Appendix K – Customer Risk Versus Due Diligence and Suspicious Activity Monitoring | 307 |
| Appendix L – SAR Quality Guidance | 308 |
| Appendix M – Quantity of Risk Matrix – OFAC Procedures | 310 |
| Appendix N – Private Banking – Common Structure | 311 |
| Appendix O – Examiner Tools for Transaction Testing | 312 |
| Appendix P – BSA Record Retention Requirements | 315 |
| Appendix Q – Abbreviations | 320 |
| Appendix R – Enforcement Guidance | 324 |
| Appendix S – Key Suspicious Activity Monitoring Components | 333 |
| Appendix T – BSA E-Filing System | 334 |