This is probably the "stupid" question of the day . . .
Last edited by Ken_Pegasus; 10/28/11 01:40 PM. Reason: Add topic
I have rewritten our BSA policy, which includes AML, CIP and OFAC and I have removed the numerous references to 31 CFR 103. . . . . .
Is it enough to state the purpose of the policy along the lines of "to meet the requirements of 31 cfr, Chapter X," or do I have to include the rest as in "to meet the requirements of X, BSA, CIP and OFAC"?