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!
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).