One new section and updates to three sections of the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual were released Wednesday by the umbrella Federal Financial Institutions Examination Council (FFIEC), which includes federal and state financial institution regulators.
The manual provides instructions to examiners for assessing an institution’s BSA/AML compliance program and its compliance with BSA regulatory requirements. Wednesday’s changes include one new section focusing on how 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 FFIEC 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, it said Wednesday’s 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.”