Agencies Update BSA/AML Examination Manual

The Federal Financial Institutions Examination Council today released long-awaited updates to its Bank Secrecy Act/Anti-Money Laundering examination manual. The updates—which do not establish new requirements—are intended to provide additional transparency and emphasize a risk-based approach to BSA/AML supervision. The manual was last updated in 2014.

Specifically, the updated manual provides instructions to examiner for tailoring BSA/AML examinations to a bank’s risk profile; assessing the adequacy of an institution’s BSA/AML compliance program; assessing a bank’s BSA/AML risk assessment processes; and developing conclusions and finalizing the exam. The agencies also made clarifications about the difference between mandatory regulatory requirements and supervisory expectations set forth in guidance.

“The agencies are aware of the uncertainty faced by financial institutions during this unprecedented time,” they said, acknowledging the COVID-19 crisis facing banks now. “The manual update, which supports tailored examination work, has been in process for an extended period and should not be interpreted as new instructions or as a new or increased focus.”