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Financial Services Law Insights and Observations

FFIEC updates BSA/AML examination manual

Agency Rule-Making & Guidance FDIC Federal Reserve OCC FFIEC NCUA Bank Secrecy Act Anti-Money Laundering Of Interest to Non-US Persons Financial Crimes

Agency Rule-Making & Guidance

On June 21, the Federal Financial Institutions Examinations Council (FFIEC) published updated versions of four sections of the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual (Manual), which provides examiners with instructions for assessing a bank or credit union’s BSA/AML compliance program and compliance with BSA regulatory requirements. The revisions can be identified by a 2021 date label on the FFIEC BSA/AML InfoBase and include the following updated sections: International Transportation of Currency or Monetary Instruments Reporting, Purchase and Sale of Monetary Instruments Recordkeeping, Reports of Foreign Financial Accounts, and Special Measures. The FFIEC notes that the “updates should not be interpreted as new instructions or as a new or increased focus on certain areas,” but are intended to “offer further transparency into the examination process and support risk-focused examination work.” In addition, the Manual itself does not establish requirements for financial institutions as these requirements are found in applicable statutes and regulations. (See also FDIC FIL-12-2021 and OCC Bulletin 2021-10.) As previously covered by InfoBytes, in February the FFIEC updated the following sections of the Manual: Assessing Compliance with Bank Secrecy Act Regulatory RequirementsCustomer Identification ProgramCurrency Transaction Reporting, and Transactions of Exempt Persons.

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