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BSA Guidelines for Night Depository Vaults

Answered by: 

Question: 
Does the FDIC’s Bank Secrecy Act provide any specific security standards relating to Night Depository Vaults?
Answer: 

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):

  • A means of protecting cash or other liquid assets, such as a vault, safe, or other secure space.
  • An alarm system or other appropriate device for promptly notifying the nearest possible law enforcement officers of an attempted or perpetrated robbery or burglary.
  • Such other devices as the Security Officer determines to be appropriate, taking into consideration:
    • 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
  • Other considerations that may be applicable include: (a) a lighting system for illuminating, during the hours of darkness, the area around the vault, if the vault is visible from outside the banking office, and (b) maintaining a camera that records activity in the banking office.



  • This Q&A originally appeared in Bankers' Hotline. For more information, sample issues, and to subscribe, click here or email bh@bankersonline.com

    First published on 10/17/2021

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