The Federal Financial Institutions Examination Council ("FFIEC") updated sections and examination procedures in its FFIEC Bank Secrecy Act / Anti-Money Laundering ("BSA/AML") Examination Manual. The FFIEC BSA/AML Examination Manual provides guidance to examiners for evaluating an institution's BSA/AML compliance program and compliance with related regulatory requirements. FFIEC stated that the updates should not be interpreted as new instructions for examiners, but should be construed as providing additional transparency regarding the examination process.
The FFIEC's updates (i) bolster its risk-focused approach toward BSA/AML examinations and (ii) provide examiners with updated information concerning transaction testing. The updates affect the following sections of the manual:
- Introduction - Assessing Compliance with Bank Secrecy Act Regulatory Requirements;
- Customer Identification Program;
- Currency Transaction Reporting; and
- Transactions of Exempt Persons.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
