BSA Policy versus your procedures

Posted By: Trees

BSA Policy versus your procedures - 09/20/05 01:34 PM

How much detail is included in your BSA Policy that goes to the board? Or, did you bundle everything (BSA, pat Act, OFAC) under an AML Policy? If so, how long is that? I'm looking at my policy statements (I did a separate one for BSA, OFAC and pat Act) and I think they are too long and include too much procedural information that should (maybe could) be excluded from the doc going to the board. I remember that, in theory, a policy statement should give an overview, designate persons for certain responsibilities, etc. but not go into the nitty gritty. Now, I don't mean, key strokes and pink slips type of information, but we do go into detail about the various methods in place to comply with BSA record keeping, etc. I am thinking that my docs. are too long.
Posted By: Princess Leia

Re: BSA Policy versus your procedures - 09/20/05 02:00 PM

Our BSA/AML policy is about 6-7 pages (keep in mind we don't have all banking products so I'd expect a full service bank to be longer. More products/risks, typically longer policy). It covers all aspects of BSA. Our CIP is referred to in the policy but is a stand alone doc - also with separate procedures (go to this website, etc...). The Policy & CIP are typically reviewed/approved by the Board at the same meeting. Additionally, we have separate procedures for SARS, OFAC compliance, FinCEN requests, and CTR filings.

What I tried to keep in mind is that if a minor procedure change is implemented, the whole policy shouldn't have to go to the Board.

Hope this helps.