The Federal Financial Institutions Examination Council (FFIEC) has released its revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. The revisions clarify supervisory expectations and incorporate regulatory changes since the manual’s 2010 update.
Significant revisions have been made in the following sections:
- Suspicious Activity Reporting
- Currency Transaction Reporting
- Foreign Correspondent Account Recordkeeping, Reporting, and Due Diligence
- Foreign Bank and Financial Accounts Reporting
- International Transportation of Currency or Monetary Instruments Reporting
- Correspondent Accounts (Foreign)
- Bulk Shipments of Currency
- Automated Clearing House Transactions
- Prepaid Access
- Third-Party Payment Processors
- Embassy, Foreign Consulate, and Foreign Mission Accounts
- Nonbank Financial Institutions
- Appendix T: BSA E-Filing System
These changes are summarized in an inter-agency statement that accompanied release of the Examination Manual, available here.
The Examination Manual emphasizes all Money Services Businesses’ responsibility to establish and maintain risk-based policies, procedures, and processes under the BSA to safeguard an organization’s operations from money laundering and terrorist financing.
The 2014 revisions were the product of inter-agency discussions among the Federal Reserve, FDIC, NCUA, OCC and the State Liaison Committee. FinCEN, the administrator of the BSA and OFAC collaborated on revisions made to sections which address compliance with the regulations and sanctions programs that FinCEN and OFAC administer and enforce. The revisions also incorporate feedback from the banking industry and examination staff.