The Federal Financial Institutions and State Regulators updates sections and related examination procedures in the BSA/AML Examination Manual
The Federal Financial Institutions Examination Council (“FFIEC”) released four updates to the Bank Secretary Act/Anti-Money Laundering (“BSA/AML”) Examination Manual, which provides guidance to examiners for evaluating a financial institution’s BSA/AML compliance program and its compliance with related regulatory requirements. The FFIEC explains that, consistent with prior updates, these “updates should not be interpreted as new instructions or as a new or increased focus on certain areas,” but are intended to “offer further transparency into the examination process and support risk-focused examination work.”
These updates affect the following items in the Manual sections (Click on the item to see more detailed information):
- International Transportation of Currency or Monetary Instruments Reporting.
- Purchase and Sale of Monetary Instruments Recordkeeping.
- Reports of Foreign Financial.
- Special Measures.
As mentioned before:
- These updates should not be interpreted as new standards or a greater focus on certain areas; rather, they offer greater transparency in the examination process and support risk-focused examination work.
- The Manual provides instructions for examiners to assess the adequacy of a bank’s or credit union’s BSA/AML compliance program and its compliance with BSA regulatory requirements.
- The Manual itself does not establish requirements for banks; Such requirements are found in statutes and regulations.
- Updated Manual sections include: (1) Purchase and Sale of Monetary Instruments Recordkeeping; (2) Special Measures; (3) Reports of Foreign Financial Accounts; and (4) International Transportation of Currency or Monetary Instruments Reporting.
- New and revised Manual sections are identified by a 2021 date on the FFIEC BSA/AML InfoBase.
- Future updates to other Manual sections will be announced as they are completed.
The updated sections of the manual more clearly outline the requirements for specific areas of AML regulation. Although the manual is directed toward examiners, its contents are useful to financial institutions as training and reference materials.
The Federal Reserve Board, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, and the State Liaison Committee worked closely with Treasury’s Financial Crimes Enforcement Network on these updates.