We are a Community Bank, regulated by FDIC. We sell Foreign Currency as an Agent of a company, only to our customers. We order the funds through a website, debit the customer's account, and credit the account specifically for Foreign Currency, that is ACH debited by the company who ships us the Foreign Currency.
Do we need to have a separate policy, since we are just an agent? And what section of the BSA AML Exam manual would this fall into to add in our policy?
Does anyone else do this?