Due diligence checklist, United States
BSA/AML (FinCEN): what to ask a vendor
Bank Secrecy Act and FinCEN regulations. FinCEN. Customer identification, monitoring and FinCEN reporting meet the BSA and the CDD Rule.
What it is
Customer identification, monitoring and FinCEN reporting meet the BSA and the CDD Rule.
Who it applies to
Applies to every financial institution in the United States, when procuring financial crime and fraud, payments, core banking, digital banking.
What to ask a vendor, and the evidence to request
| # | Ask the vendor for | Evidence to request |
|---|---|---|
| 1 | Customer identification and beneficial ownership collection to the CIP and CDD Rules | The identification and verification methods supported, the rules they follow, and the record kept for each check. |
| 2 | Suspicious activity and currency transaction reports filed with FinCEN electronically | A description of the reports the system produces for the regulator, the formats, and how they are lodged, with a sample. |
| 3 | OFAC sanctions screening | The screening lists in use, how often they are updated, and a sample of the screening record a case produces. |
In every case
- A named contact at the vendor responsible for this regime, and how the vendor tracks changes to it.
- Which named customers the vendor already serves under this regime, as references you may call.
This checklist is a starting point for a procurement team, not legal advice. Read it with the regulator's own page, your institution's policies and your legal and risk teams; the regime may have changed since the date on this document.
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