Federal and State Regulators Release Updates to the BSA/AML Examination Manual

(Dec. 1, 2021) – The Federal Financial Institutions Examination Council (FFIEC) today released one new section and updates to three sections of the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. Today’s updates affect the following sections:

• Introduction - Customers (new)
• Charities and Nonprofit Organizations
• Independent Automated Teller Machine Owners or Operators
• Politically Exposed Persons

The updates should not be interpreted as new requirements or as a new or increased focus on certain areas. Rather, these sections provide information and considerations related to certain customers that may indicate the need for bank policies, procedures, and processes to address potential money laundering, terrorist financing, and other illicit financial activity risks. These sections provide further transparency into the BSA/AML examination process.

The sections also remind examiners that no specific customer type automatically presents a higher risk of money laundering, terrorist financing, or other illicit financial activity. Further, banks that operate in compliance with applicable BSA/AML requirements and reasonably manage and mitigate risks related to the unique characteristics of customer relationships are neither prohibited nor discouraged from providing accounts or services to any specific class or type of customer.

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. FFIEC agencies worked closely with Treasury’s Financial Crimes Enforcement Network on today’s updates.

Attachments:

• Introduction – Customers
• Charities and Nonprofit Organizations
• Independent Automated Teller Machine Owners or Operators
• Politically Exposed Persons