Another BSA Order

Asian Bank of Philadelphia, PA is one of the latest banks to face a BSA and OFAC compliance enforcement order from the Federal Reserve. Under the order, Asian Bank is required to develop a written BSA compliance program, giving special attention to the purchase of monetary instruments by non- accountholders and to funds transfers. A procedure for checking the current OFAC list and placing appropriate blocks is also required by the agreement. The agreement also calls for a regular, comprehensive independent audit.

For Asian Bank, CIP is not enough. The bank must develop a customer due diligence program designed to identify and trigger prompt reporting of suspicious activity. The due diligence program includes a comprehensive analysis of customer risk.

Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 2, 2/05