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AML Disclosures

Bank of China US Branches BSA/AML and Sanctions Statement


Bank of China Limited (“BOC”) is organized under the laws of the People’s Republic of China and maintains branches globally, including in the United States of America (“U.S.” or “U.S.A”). BOC’s banking operations in the U.S. consist of branches in New York, Queens, Chicago, and Los Angeles (collectively, “BOC U.S.A.”). The New York and Queens branches are Federal Deposit Insurance Corporation (“FDIC”) insured branches licensed and examined by the Office of the Comptroller of the Currency (“OCC”). The Chicago and Los Angeles BOC U.S.A. branches are uninsured branches that also 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 Bank Secrecy Act (“BSA”) as amended by the U.S.A. PATRIOT Act.

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 approved BSA/AML Program establishes BOC U.S.A.’s minimum standards to which all AML-related policies and implementing procedures must adhere.

As part of a 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 BOC U.S.A.’s operations, including to all employees, contractors and contingent workers 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.


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 the U.S. Department of Treasury’s Office of Foreign Assets Control (“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.


BOC U.S.A.’s sanctions compliance programs intend 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 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 BOC Group's Certification Regarding Correspondent Accounts for Foreign Banks.


USA Patriot Act Certification with list of covered oversea branches and subsidiaries

Please click here for BOC U.S.A.’s Certification Regarding Correspondent Accounts for Foreign Banks. 

[1] Refer to the Department of the Treasury, A Framework for OFAC Compliance Commitments (“OFAC Framework”) (, published on May 2, 2019.