What must a Members internal policies, procedures, and controls cover?
A Member’s policies, procedures, and controls should include a customer identification program; procedures to monitor for and report suspicious customers and transactions; procedures to respond to Section 314(a) information requests; due diligence programs for certain correspondent and private banking accounts; and procedures to comply with the Office of Foreign Assets Control’s rules and with Section 311 Special Measures. See the Interpretive Notice 9045 for more information.
