Banking and Finance Law Daily FFIEC updates BSA/AML examination manual
Friday, February 26, 2021

FFIEC updates BSA/AML examination manual

By Colleen M. Svelnis, J.D.

The FFIEC released updated versions of four sections of the Examination Manual: Assessing Compliance with BSA Regulatory Requirements; Customer Identification Program; Currency Transaction Reporting; and Transactions of Exempt Persons.

The Federal Financial Institutions Examination Council (FFIEC) has released updates to four sections of the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual, which provides instruction to examiners for assessing a bank’s BSA/AML compliance program and its compliance with BSA regulatory requirements. The four updated sections are Assessing Compliance with BSA Regulatory RequirementsCustomer Identification ProgramCurrency Transaction Reporting, and Transactions of Exempt Persons. The updates are not intended to be construed as new instructions or as a new or increased focus on certain areas; instead, the updates are intended to offer further transparency into the examination process and support risk-focused examination work. In addition, the manual itself does not establish requirements for financial institutions since these requirements are found in applicable statutes and regulations.

According to the FFIEC, the Federal Reserve Board, the Federal Deposit Insurance Corporation, National Credit Union Administration, Office of the Comptroller of the Currency, and the State Liaison Committee worked closely with the Financial Crimes Enforcement Network on the updates. The updated sections reinforce the risk-focused approach to BSA/AML examinations, as well as include updated information for examiners regarding transaction testing, including examples.

The FDIC issued a Financial Institution Letter (FIL-12-2021) alerting its supervised institutions to the Examination Manual updates, while the OCC released a Bulletin (OCC Bulletin 2021-10) highlighting the updates.

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