Enforcement of the Bank Secrecy Act The Federal Reserve has also taken a number of recent enforcement actions to require depository institutions to improve their BSA programs and comply with other anti-money laundering obligations, including the reporting requirements that exist under the BSA.
While bank holding companies are not statutorily mandated to have the same program requirements as depository institutions, we have also taken action against bank holding companies to require them to improve their oversight of the subsidiary bank’s BSA programs and compliance.