BSA/AML professionals have been anxiously waiting revisions to the 2014 BSA/AML Examination Manual (Exam Manual) published by the Federal Financial Institutions Examination Council (FFIEC), the interagency body comprised of federal banking regulatory agencies. On April 15, 2020, the FFIEC released an interagency statement announcing updates to four sections of the Exam Manual. According to the FFIEC, these are the first of several phases of updates that will be released. In the statement, the agencies addressed the uncertainty faced by financial institutions during this unprecedented time.
The Exam Manual was originally intended to provide instructions to examiners when assessing the adequacy of a financial institution’s BSA/AML compliance program when it was first published in 2005. It is also widely used among industry professionals as expected guidance for establishing a sound BSA/AML program even though not all content is regulatory authority.