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BSA Manuel & Enhance Due Diligence

Answered by: 
Randy Carey
Jim Bedsole

Question: 
I started in BSA a few years ago and I built an Enhance Due Diligence program for higher risk customers with monthly transaction review and then yearly comprehensive review of the business and its expected vs actual activity. At the time I found a really clear outline of expectations in the BSA Manual and now I can't find anything related to EDD at a all. Did this get removed? Anyone else experiencing this?
Answer: 

by Randy Carey:

Not really sure. The BSA Exam Manual has not been updated since 2014.

Answer: 

by Jim Bedsole:

Look starting on p. 57 of the FFIEC BSA/AML Exam Manual v2. Also, in the index on p. Index-10 there is an index entry for all of the references of Enhanced Due Diligence. That should get you to where you need to go.

First published on 01/26/2020

Filed under: 
Compliance
Filed under lending as: 
Bank Secrecy Act

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