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Standard Procedures Manuals (SPM)

Bank Secrecy Act Compliance September 2023

BCG Standard Procedures Manual #21, Bank Secrecy Act Compliance, provides a comprehensive discussion of the Bank Secrecy Act and other related laws and also the regulations issued by FinCEN and the federal banking agencies, all of which are designed to prevent money laundering and drug trafficking activities, as well as terrorist financing.

The Manual provides extensive discussions of these topics:

  • Bank Secrecy Act/Anti-money Laundering compliance program requirements, including the Five Pillars of Compliance and the customer due diligence and beneficial ownership rules;
  • The Corporate Transparency Act and FinCEN’s new Final Rule requiring a reporting company to file with FinCEN information about the beneficial owners of the reporting company (the Final Rule is effective January 1, 2024);
  • BSA recordkeeping and reporting requirements, including Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs);
  • Information-sharing rules under Section 314 of the USA PATRIOT Act;
  • Due diligence requirements for foreign correspondent and private banking accounts under Section 312 of the USA PATRIOT Act;
  • Prohibition against providing correspondent accounts to foreign shell banks;
  • General discussion of the FFIEC’s BSA/AML Examination Manual;
  • California’s anti-money laundering laws;
  • Providing banking services to high-risk businesses, such as money service businesses, third-party payment processors and marijuana- and hemp-related businesses;
  • OFAC compliance requirements; and
  • General requirements of the Unlawful Internet Gambling Enforcement Act of 2006
The text of the Manual is 479 pages, plus 61 pages of appendixes.


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SPM 21
* Janet Bonnefin is retired from the practice of law with the firm.
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