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AML AND Sanctions Disclosures

BOC U.S.A.’s BSA/AML and Sanctions Statements

Bank of China Limited is organized under the laws of the People’s Republic of China and maintains branches globally. BOC’s banking operations in the U.S. – namely BOC U.S.A. – consists of branches in New York, NY, Queens, NY, Chicago, IL and Los Angeles, CA. BOC U.S.A.’s insured and uninsured branches are licensed and examined by the OCC. 

BSA/AML Statement

BOC U.S.A. is committed to complying with all applicable U.S. laws and regulations designed to combat money laundering, criminal activity and terrorist financing, including the BSA as amended by the USA PATRIOT Act and related statutes.

BOC U.S.A. has adopted a BSA / Anti-Money Laundering (“AML”) Compliance Policy and Program (“BSA/AML Program”) to help ensure that BSA/AML risks identified are appropriately mitigated and to help ensure BOC U.S.A. complies with the requirements and obligations set out in U.S. legislation, regulations, rules and industry guidance for the financial services sector. The board of directors of BOC approved the BSA/AML Program that establishes BOC U.S.A.’s minimum standards to which all AML-related policies and implementing procedures must adhere.

As part of BOC U.S.A.’s comprehensive risk governance framework, the BSA/AML Program is managed based on the three lines of defense model designed to assure independence from each other and multiple levels of risk control.

The BSA/AML Program applies across all of BOC U.S.A.’s operations to protect BOC U.S.A. from being misused for money laundering, terrorist financing or other illegal purposes. In the event BOC U.S.A. engages a third-party service provider to assist with all or part of BOC U.S.A.’s BSA/AML Program, that third-party service provider will be required to comply with the BSA/AML Program.

US Sanctions Statement

BOC U.S.A. is committed to complying with all applicable U.S. laws and regulations, including all economic and trade sanctions related programs and regulations as administered and enforced primarily by OFAC. BOC U.S.A. is committed to conducting business in accordance with the highest ethical standards and in full compliance with both the letter and spirit of all applicable laws and regulations.

OFAC strongly encourages organizations subject to U.S. jurisdiction, foreign entities that conduct business in or with the U.S., U.S. persons, and those using U.S. origin goods or services, to employ a risk-based approach to sanctions compliance by developing, implementing, and routinely updating a sanctions compliance program.[1] Accordingly, BOC U.S.A. takes steps to mitigate potential compliance, regulatory, or reputational risk associated with violations of sanctions laws and regulations, and the risk of conducting business with sanctioned parties.

All payment transactions, including international funds transfers, also are subject to applicable laws and regulations, including operational and processing policies and procedures adopted by BOC U.S.A.

BOC U.S.A.’s sanctions compliance program is intended to:

  • Ensure compliance with economic sanctions programs promulgated by the U.S. Government;
  • Raise personnel awareness and promote the detection and reporting of sanctions-related activity internally and, when required, to government authorities through identified channels of escalation;
  • Help ensure that all of BOC U.S.A. and its staff conduct business in compliance with all applicable sanctions-related laws and regulations, and provide services to customers in conformity with BOC U.S.A.’s established risk appetite;
  • Promote strong governance and risk management throughout BOC U.S.A. to properly manage and mitigate sanctions compliance risks;
  • Provide BOC U.S.A. with sanctions-related guidance, standards, and expectations to be implemented within the U.S.; and
  • Help ensure full cooperation with regulatory and law enforcement authorities in civil and criminal investigations, prosecutions, and forfeiture actions relating to sanctions violations.

Wolfsberg Questionnaire

Please click here for the BOC U.S.A.’s Questionnaire.


USA Patriot Act Certification 

Please click here for BOC Group’s Certification. 


[1] Refer to the Department of the Treasury, A Framework for OFAC Compliance Commitments,