Is anyone including reference to USAPA 314 in their BSA Policy? I'm inclined to think it warrants inclusion, but I have not found any official directive. On a related note, are your internal auditors reviewing the 314(a) search process during the BSA audits?

This is exactly why I posted my question earlier regarding the BSA Policy as it relates to applicable sections of the PATRIOT Act, OFAC, and & AML. From an internal auditor perspective, I would think section 314 would be included in the BSA audit. As far an audit procedure, there is no guidance for internal auditors other than noting whether the bank is adhering to the requirements. The BOL Tools has some useful sources (Cheat Sheet, Compliance Checklist) to utilize.
But I'm still hoping someone will be gracious enough to share and submit their inclusive BSA policy.
The problem with a thorough BSA audit program is that I keep finding more steps to add and it seems this audit will never END!!!!!!!!!!!!!! The BSA audit program and internal control questionnaire I submitted in April 2003 needs updating now to include testing for compliance with the PATRIOT Act.

Now you've really got my wheels turning. Our AML Policy is separate from our BSA Policy. Now I'm wondering if 314 belongs in AML instead of BSA. That, of course, assumes it needs to be plugged into a policy at all....

From all threads that I can recall regarding BSA policies, I noted that AML could be incorporated into the BSA policy. And now you got the CIP that will be a part of BSA. I can see a comprehensive BSA policy that would include all this b/c the AML and BSA required elements for the compliance program overlap.
I've read so much "stuff" until I don't think my lil brain can absorb not one more article, etc. regarding BSA and the rest.

The request come from FinCEN. I associate that with large currency transactions ad SAR reporting, which is BSA and so goes 314a request. Therefore, I am now placing this in BSA and also CIP under government lists since BSA is a federal regulation and this way I will be covered somewhere for you lonely auditors.

314(a) requests are specifically noted as single-serving searches. The instructions indicate that they are not to be retained for comparison to new customers. Similarly, the final rule for CIP state that no government lists designated for CIP purposes even exist yet. But if/when such lists are created, they will be designated as lists to use for CIP. So the practice of comingling CIP and 314 is not necessary.

YES. 314 a & b should be included in your BSA/AML policy. We just went through an exam and the examiners want it there.

Who is your regulator? Mine looked at my CIP draft, and said I had covered all the regulatory requirements. 314 stuff is not in mine.

Lestie,
Was your regulator looking at your whole BSA policy, or just the CIP program?

Either way, I've decided to add 314 to the BSA policy. I can't imagine any regulators dinging us for having it in there.

The whole thing - but I can't imagine being criticized for including it either.