Excellent question. We recommend that you review this question with your legal or compliance team; however, we believe that the BSA does establish minimum security standards for Night Depository Vaults – under the discretion of the designated Security Officer. Those standards include a (1) vault or safe, (2) alarm system, (3) adequate lighting inside the building, and (4) a camera based on risk, costs and other security measures and physical characteristics of the branch office.
Subpart A – Minimum Security Procedures, § 326.3 Security program setting forth security standards. The Security Program shall: provide for selecting, testing, operating, and maintaining appropriate security devices as specified in paragraph (b) of this section: Each institution shall have, at a minimum, the following security devices (condensed and paraphrased):
- The incidence of crimes against financial institutions in the area
- The amount of currency or other valuables exposed to robbery, burglary, and larceny
- The cost of security devices
- Other security measures in effect at the banking office, and
- The physical characteristics of the structure of the banking office and its surroundings