On April 15th, FinCEN released updates to the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. There are 41 pages of new instructions and directions for the examiners coming into your bank to evaluate your BSA/AML Program. It discusses things they should consider while scoping and planning for the review, what kind of testing should be conducted, and important factors to focus on while developing conclusions.
On the bright side, this new material sheds light on what the regulatory expectations are when it comes to “risk-focused BSA/AML supervision” discussed in the Joint Statement on the Risk-Focused Approach to BSA/AML Supervision that was put out in July 2019.
One of the most interesting changes discusses the objectives when scoping and planning for an exam:
“Objective: Develop an understanding of the bank’s money laundering, terrorist financing (ML/TF), and other illicit financial activity risk profile.”
“ML/TF” pops up 53 more times and appears to primarily replace the more general term “BSA/AML Risk”. While there is no statement from the regulators indicating exactly what this shift is intended to mean, it is clear that banks will be expected to adequately identify and assess the ML/TF and other illicit financial activity risks within its banking operations.
We will be going through all 41 pages of updates in our webinar, The New BSA/AML Exam Manual. Be sure to join us this Thursday, April 30th, as we will not only discuss the changes themselves but also what they could mean for your BSA/AML program and your next exam!