This is probably the "stupid" question of the day . . .
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"?

Thanks.

We use the regulatory citation in our policy (31 CFR).

And there are no stupid questions! Sometimes you just need to talk it out!