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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 (BSA/AML) compliance program requirements,
including customer due diligence and the recent trend to use the term AML/CFT in lieu of
BSA/AML;
- The Corporate Transparency Act and FinCEN’s new Final Rules 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) and financial institution access to
that information;
- 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 493 pages, plus 61 pages of appendixes.
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Compliance Companion
Compliance Companion® is a one-stop regulatory compliance resource for financial institutions.
This online compilation of 19 industry-leading compliance manuals, including this SPM #21, Bank Secrecy Act Compliance, takes the legalese out of federal and California laws and regulations, making
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