On February 25, 2021, the FFIEC announced revisions to the BSA/AML Examination Manual.
Specifically, the FFIEC added a new introduction in the “Assessing Compliance with BSA Regulatory Requirements” section and made revisions to three additional sections:
1) Customer Identification Program;
2) Currency Transaction Reporting; and
3) Transactions of Exempt Persons
It’s important to remember this manual serves as a guide for examiners when determining whether an institution’s BSA/AML compliance program is adequate. If you want to know what the examiners will be looking at during your next BSA/AML exam, this is where you want to look for guidance.
These new and revised sections do not impose any new requirements, but they do offer further transparency into the examination process and support risk-focused examination work. All of the revisions are identified by a 2021 date on the FFIEC BSA/AML InfoBase.
Be sure to check out our monthly magazine, Banking on BCC, as we plan to take a closer look at these revisions in an upcoming issue.
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them.
Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).