August 10, 2023

The Next Best Seller? FFIEC BSA Exam Manual Updates

It’s been a hot minute, but last week the FFIEC rolled out updates to BSA/AML Examination Manual. For those playing at home, it was 2021 the last time any updates were made. Bestsellers are not written overnight, I guess. Well for those still looking for a great summer beach read, your wait is over! Grab your lawn chair, sunscreen, and a cold one – then settle in for some high octane reading!

Six sections were included with this latest update, and all can be found in the “Assessing Compliance with BSA Regulatory Requirements” portion of the online manual. Those sections specifically are:

  • Special Information Sharing Procedures
  • Due Diligence Programs for Correspondent Accounts for Foreign Financial Institutions
  • Due Diligence Programs for Private Banking Accounts
  • Prohibition on Correspondent Accounts for Foreign Shell Banks: Records of Owners and Agents
  • Summons or Subpoena of Foreign Bank Records
  • Reporting Obligations on Foreign Bank Relationships with Iranian-Linked Financial Institutions

Per the accompanying announcement that rolled out the updated sections, financial institutions should not consider these revisions to be new instructions or reflect an increased area of focus by examiners. Rather, the updates are intended to clarify past instructions and support risk-focused examinations. Obviously, depending on your institution’s own products, services, and customer base, some of these sections may not impact you at all.

While it might not be the gripping page turner you were searching for, it’s still good to know that the regulators are continuing to review and modify the exam manual slowly but surely. Who knows, maybe the next revisions will be authored by James Patterson or Colleen Hoover. We can always hope!

You can find the FFIEC’s announcement from last week at this link: https://www.ffiec.gov/press/an080223.htm

And the BSA/AML Examination Manual can be located at: https://bsaaml.ffiec.gov/manual

Authored by: Joann Lang, CAMS, CIA, CCBP

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