Bank Secrecy Act, anti-money laundering, Office of Foreign Assets Control

I want to know about…

• BSA/AML/OFAC regulations
• BSA/AML supervision and regulation letters
• BSA/AML guidance
• BSA/AML resources
• OFAC guidance and resources
• Contacts

BSA/AML/OFAC regulations

• 31 CFR Chapter X—Bank Secrecy Act
• Regulation H, PART 208 Subpart F—Membership of State Banking Institutions in the Federal Reserve System
• Subpart F—Other Requirements
• Regulation K, Part 211—International Banking Operations
• Subpart A—International Operations of U.S. Banking Organizations
• Subpart B—Foreign Banking Organizations
• Regulation Y, Part 225—Bank Holding Companies and Change in Bank Control
• Subpart A—Components of a Response Program
• 31 CFR Chapter V—Office of Foreign Assets Control
• All Regulations

BSA/AML/OFAC supervision and regulation (SR) letters

BSA/AML/OFAC Supervisory Policy and Guidance Topics—SR letters address significant policy and procedural matters related to the Federal Reserve System's supervisory responsibilities and outlines expectations and priorities or articulates views regarding appropriate practices for a specific subject.

• SR 22-5—Joint Statement on the Risk-Based Approach to Assessing Customer Relationships and Conducting Customer Due Diligence
• SR 21-18—Release of New and Updated Sections of the Federal Financial Institutions Examination Council's Bank Secrecy Act/Anti-Money Laundering Examination Manual
• SR 21-10—Interagency Statement on the Issuance of the Anti-Money Laundering/Countering the Financing of Terrorism National Priorities
• SR 21-8—Interagency Statement on Model Risk Management for Bank Systems Supporting Bank Secrecy Act/Anti-Money Laundering Compliance
• SR 21-2—Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations
• SR 19-19—Bank Exams Tailored to Risk (BETR)

BSA/AML guidance

The Federal Financial Institutions Examination Council (FFIEC) Bank Secrecy Act/Anti-Money Laundering Infobase and Examination Manual and Procedures (BSA/AML Manual) provides guidance to examiners and financial institutions on the characteristics of an effective BSA/AML program. Details can be found at the following:

• FFIEC Main Page
• BSA/AML InfoBase
• BSA/AML Examination Manual
• BSA/AML Examination Procedures
• BSA/AML References
• BSA/AML Regulations for Banks

The Financial Crime Enforcement Network (FinCEN) is a bureau of the United States Department of the Treasury delegated with the authority to administer the BSA. Additionally, they collect, maintain, analyze, and disseminate information about financial transactions to combat domestic and international money laundering, terrorist financing, and other financial crimes. Details can be found at the following:

• FinCEN Main Page
• BSA E-Filing System
• Statute and Regulations
• FinCEN Guidance
• FinCEN Assistance
• Recent Advisories/Notices/Bulletins/Fact Sheets
• Answers to Frequently Asked BSA Questions

BSA/AML resources

• Corporate Transparency Act (CTA)—Beneficial Ownership Information (BOI) Reporting (September 29, 2022)
• FinCEN AML/CFT Priorities (June 30, 2021)
• National Defense Authorization of Act—AML Act of 2020 (January 1, 2021)
• Ask the Fed: Governor Michelle Bowman and Director Kenneth A. Blanco of FinCEN to Discuss Recent Anti-Money Laundering (AML) Efforts (November 2020)
• BSA Timeline (1970 to Present)
• 11th District Staff AML/BSA-Related Publications and White Papers

OFAC guidance and resources

• Sanctions Programs and Information
• Sanctions Program and Country Information
• OFAC Frequently Asked Questions
• Contact OFAC

Contacts

• Lorenzo Garza, Vice President
• Meeoak Cho, Assistant Vice President
• Ask a Question
• Request a Speaker

Publications and white papers

The views expressed in these publications do not necessarily reflect the official positions of the Federal Reserve Bank of Dallas or the Federal Reserve System.

• “Four Steps to Implementing Robust AML Risk Management for U.S. Insurers,” Raja Qasim, CAMS, CFE, CISA, Senior Risk Examiner, December 8, 2021
  This article summarizes four key steps for insurers’ implementation of a risk-based BSA/AML compliance program. Once management understands the law and associated rules and regulations and is aware of nuances unique to the insurance sector, an effective product-based program can be established.
• “All Hat, No Cattle: What the AML Professional Needs to Know About Cattle Fraud,” Brigette K. Miller, CAMS-FCI, CRCM, Senior Risk Specialist, June 25, 2019
  This white paper discusses how cattle fraud is an increasingly large source of illicit funds, much of which is subsequently laundered through financial institutions. This paperIt also explores some recent and significant cattle frauds, as well as how financial institutions can guard against fraudsters attempting to conduct money laundering through the financial system.
• “Bank Secrecy Act Auditing for Community Banks: A Risk-Based Approach,” Susan Cannon, CAMS-Audit, BSA/AML Supervision and Risk Coordinator, August 6, 2015
  This white paper discusses specific strategies for achieving compliance with the independent testing pillar for smaller banks, often referred to as “community banks,” commensurate with their BSA/AML risk profile.

ACAMS membership required

• “The Beef With Cattle Fraud,” Brigette K. Miller, CAMS-FCI, CRCM, Senior Risk Specialist, July 1, 2020
  Cattle fraud is a preventable crime if one is willing to invest some time and energy. This article explores examples of recent cattle fraud cases, fraud prevention, and the road ahead with new technologies.
• “Small Institution Strategies for Outsourcing BSA Audits,” Susan Cannon, CAMS-Audit, BSA/AML Supervision and Risk Coordinator, September 4, 2019
  Based on concepts in existing supervisory guidance, this article provides pointers for smaller institutions considering outsourcing BSA/AML independent testing for the first time or looking to switch to another firm.