As if you needed one more thing to add to your “to do” list, the FFIEC released an update to the BSA Exam Manual on April 29, 2010. Will it ever end? You can access the 2010 version of the manual on the FFIEC BSA/AML InfoBase. Rest assured we will be dissecting the changes and will update you in future blogs and/or newsletter articles.
The release states that the 2010 version further clarifies supervisory expectations since the August 24, 2007, update. The revisions again draw upon feedback from the banking industry and examination staff. You can easily locate sections that had significant changes as they are designate with “2010” next to them in the table of contents. Below are just a few of the sections that had significant changes:
BSA/AML Compliance Program Structures – Substantially reworked the section on Enterprise-Wide BSA/AML Compliance programs to discuss the variety of BSA/AML compliance programs that exist, reflect current supervisory expectations, and enhance the specific discussion of consolidated compliance programs. The section is now titled “BSA/AML Compliance Program Structures.”
Core Examination Procedures for Assessing the BSA/AML Compliance Program – Streamlined and reorganized the core examination procedures for assessing the BSA/AML compliance program to make them more logical.
Currency Transaction Reporting Exemptions – Updated the section to reflect the changes in the regulation and FinCEN guidance in this area.
Suspicious Activity Reporting – Enhanced the discussion of methods to identify, research, and report suspicious activity. Reorganized the section to reflect current supervisory expectations and made the discussion easier to follow and more user-friendly. Added a new Appendix S to illustrate the interaction between the different components of a suspicious activity monitoring program.
Automated Clearing House Transactions – Updated the section to reflect the recent changes to international Automated Clearing House transactions. Made corresponding changes to the OFAC section.
Electronic Cash – Revised the section to include a more in-depth discussion of Prepaid Cards.
Electronic Banking – Updated the section (specifically, the Remote Deposit Capture discussion) to reflect the FFIEC guidance, Risk Management of Remote Deposit Capture (January 14, 2009).
Third-Party Payment Processors – Updated the section to reflect recent agency guidance, Guidance on Payment Processor Relationships, FDIC FIL-127-2008 (November 7, 2008), and Risk Management Guidance: Payment Processors, OCC Bulletin 2008-12 (April 24, 2008).