Bank Secrecy Act/Anti-Money Laundering Examination Manual Update

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The Federal Financial Institutions Examination Council (FFIEC) has issued updates to its Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual to enhance examination process transparency and facilitate risk-focused execution. As these changes unfold, Treliant stands ready to support financial institutions in navigating these changes by assisting in the review of their Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) programs. This includes conducting risk assessments, updating policies and procedures as needed, training staff on the revised examination procedures, and providing ongoing monitoring and compliance support to meet updated guidelines.


FFIEC has updated sections of the FFIEC BSA/AML Examination Manual, which provides guidance for assessing a bank’s AML/CFT program and its adherence to corresponding regulatory requirements. The updates address various areas, including due diligence programs for correspondent accounts for foreign financial institutions, prohibition on correspondent accounts for foreign shell banks, reporting obligations on foreign bank relationships with Iranian-linked financial institutions, and due diligence programs for private banking accounts.

It is important to note that these updates do not establish new requirements for financial institutions, nor should they be interpreted as increased focus on certain areas. Instead, they aim to provide further transparency into the examination process and support risk-focused examination work.

For more information, please consult the updated FFIEC BSA/AML Examination Manual sections on the FFIEC BSA/AML Infobase at the links above as well as reviewing their change logs. Future updates to other manual sections will be announced as they are completed.

This Takeaway was authored by Richard Lee