So once upon a time trust companies that were not subject to regulation by a federal regulator are exempt from the requirement of establishing an AML Program under 1010.205. CTR and SAR filing are still required.
However, FinCEN Issued a proposed rulemaking in August 2016 to eliminate this exception for trust companies.https://www.federalregister.gov/doc...dering-programs-and-beneficial-ownership
I don't see that it is final, but it is coming. Also, some states may already expand the requirements to trust companies even if FinCEN hasn't finalized its rule. The FFIEC Exam Manual section applies to federally regulated banks that have a trust department as part of the ban itself, rather than an affiliate.
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