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OCC examiners review compliance with BSA as part of every exam cycle using the core and expanded examination procedures contained in the FFIEC’s Bank Secrecy Act/Anti-Money Laundering Examination Manual.
Core Examination Procedures focus on
- Assessing the BSA/AML Compliance Program and address areas such as scoping and planning and the BSA/AML risk assessment and compliance program.
- Regulatory Requirements and Related Topics which include the customer Identification program, customer due diligence, suspicious activity reporting, funds transfers recordkeeping, foreign correspondent accounts, OFAC and other topics.
Expanded Examination Procedures focus on
- Enterprise-Wide Compliance Programs, Foreign Offices of U.S. Banks, and Parallel Banking covering enterprise-wide BSA/AML compliance programs, foreign branches and offices of U.S. banks and parallel banking.
- Products and Services such as foreign and domestic correspondent banking, U.S. dollar drafts, private and electronic banking, funds transfers and trade finance activities.
- Persons and Entities including nonresident aliens and foreign individuals, politically exposed persons (PEPs), non-bank financial institutions and professional services providers.