BSA/AML Examination Manual - ffiec

Appendix P: BSA Record Retention Requirements
• Agencies and instrumentalities of federal, state, local, or foreign governments.
• Judges, public officials, or clerks of courts of record as custodians of funds in
controversy or under the control of the court.
• Certain aliens as specified in 31 CFR 103.34(a)(3)(iii-vi).
• Certain tax exempt organizations and units of tax-exempt organizations (31 CFR
103.34(a)(3)(vii)).
• A person under 18 years of age with respect to an account opened as a part of a
school thrift savings program, provided the annual dividend is less than $10.
• A person opening a Christmas club, vacation club, and similar installment savings
programs, provided the annual dividend is less than $10.
• NRAs who are not engaged in a trade or business in the United States.
Suspicious Activity Report and Supporting Documentation
A bank must maintain a record of any Suspicious Activity Report (SAR) filed and the
original or business record equivalent of any supporting documentation for a period of
five years from the date of filing.
Currency Transaction Report
A bank must maintain a record of all Currency Transaction Reports (CTRs) for a period
of five years from the date of filing.
Designation of Exempt Person
A bank must maintain a record of all designation of persons exempt from CTR reporting
as filed with the Treasury (i.e., FinCEN Form 110) for a period of five years from the
designation date.
Customer Identification Program
A bank must maintain a record of all information it obtains under its procedures for
implementing its Customer Identification Program (CIP). At a minimum, these records
must include the following:
• All identifying information about a customer (e.g., name, date of birth, address, and
TIN).
• A description of the document that the bank relied upon to identity of the customer.
• A description of the nondocumentary methods and results of any measures the bank
took to verify the identity of the customer.
FFIEC BSA/AML Examination Manual P–5 8/24/2007