Amending BSA Policy to Include Section 314(a) Requests

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Question:

Should we amend our BSA policy to include information regarding Section 314a Information Requests? If so, do you have any samples of what should be included?

Answer:

I am a proponent of grouping similar subjects together for a single policy. I think that it is effective to combine BSA, OFAC, and USA PATRIOT Act requirements into a single policy. These laws all require similar and related actions, which is what is important for purposes of policies and procedures. As for samples, I'm sure there will be folks willing to share.

First published on BankersOnline.com 05/12/03