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Five Necessary Elements For Compliance
Dan Soto, Special Counsel for the Federal Reserve Board of Governors, said in a presentation for the Institute of International Research in New York City, that there were four elements necessary for a financial institution to be in compliance with BSA. The four are: (1) Written Policies and Procedures, (2) A BSA Officer, (3) Outside testing, and (4) Training.
Dan said that by the end of 1995, a fifth requirement may be in place-a written "Know Your Customer" policy.
Copyright © 1994 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 5, No. 3, 11/94
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