Agencies Update BSA/AML Examination Manual

The Federal Financial Institutions Examination Council today released 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 updates address: transactions of exempt persons; currency transaction reporting; customer identification program. They also include a new introduction on assessing compliance with BSA regulatory requirements.

The agencies also made clarifications about the difference between mandatory regulatory requirements and supervisory expectations set forth in guidance. “The manual provides instructions to examiners for assessing 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,” they said.