(Dec. 3, 2021) One new section – focusing on assessments of money laundering practices — and updates to three existing parts of the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual were released this week by the FFIEC.
The manual provides instructions to examiners for assessing an institution’s BSA/AML compliance program and its compliance with BSA regulatory requirements. The changes released this week include the new section focusing on how credit unions and other financial institutions assess money laundering and terrorist financing risks (if any) posed by their customers.
The other updates revise the manual’s current sections on charities and nonprofit organizations; independent automated teller machine (ATM) owners or operators; and politically exposed persons.
The exam council said examiners are reminded that no specific customer type automatically presents a higher risk of money laundering, terrorist financing, or other illicit financial activity. “Further,” the council noted, “banks that operate in compliance with applicable BSA/AML requirements and reasonably manage and mitigate risks related to the unique characteristics of customer relationships are neither prohibited nor discouraged from providing accounts or services to any specific class or type of customer.”
Additionally, the exam council said the updates should not be seen as new requirements or suggest a new or increased focus on certain areas. “Rather, these sections provide information and considerations related to certain customers that may indicate the need for bank policies, procedures, and processes to address potential money laundering, terrorist financing, and other illicit financial activity risks,” the council noted. “These sections provide further transparency into the BSA/AML examination process.”