Can We Combine our BSA, OFAC & CIP Policies?

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Question:

We have separate policies for our BSA program, OFAC and CIP. Can we combine them or are do they have to remain separate?

Answer:

CIP and OFAC programs serve unique purposes, but I agree that they are closely related to BSA/AML if for no other reason than they are often treated as a package by examiners. It seems reasonable to wrap CIP and OFAC up into the broader policy for compliance with BSA/AML laws and regulations. However, I strongly recommend that CIP compliance and OFAC compliance are maintained as identifiable units in that overall policy.

First published on BankersOnline.com 9/08/08