While Bank Secrecy Act requirements, including the provisions added by the USA PATRIOT Act, generally do not extend to foreign operations of U.S. banking organizations, the Federal Reserve is interested in understanding the global operations of the banking organizations under Federal Reserve supervision as a matter of safety and soundness.
There was advanced consultation with the Bank in relation to the development of auditing guidance for auditors of banks and the same process will take place in relation to auditing guidance for other firms regulated by the Bank.