Hi All,

I remember reading some items needed for record retention. Example: Checks in Excess of $100: Each check, draft, or money order drawn on the bank or issued and payable by it that is in excess of $100. I know there are more. Does anyone know where I can find that information? Also is it required to be included in a BSA/AML policy?

Refer to Appendix P in the Examination Manual.

Beyond "the pillars," there is no official guidance about what should be included in a BSA/AML policy. My personal suggestion is that you address each of the "core" examination topics as listed in the FFIEC Manual.

As there are exam procedures for reviewing monetary instrument sales and wire transfers, but none for the "general" record retention requirements, I would combine all three of them under the same heading.

As rlcarey implies, do not reiterate legal requirements in your policy; incorporate them by reference such as a mention of Schedule P. (Make certain that its content doesn't change as future editions are published.)