The FFIEC BSA/AML Examination Manual was revised in 2026 and while the revisions do not create new legal requirements, they can help BSA Officers and AML/CFT staff prepare for BSA exams. The recent updates do not introduce sweeping new requirements. Instead, they reinforce a consistent regulatory expectation that institutions understand their unique risks, document the rationale behind their compliance decisions, and maintain controls that evolve alongside an increasingly complex financial crime landscape.
As a strategic resource, the FFIEFC BSA/AML Examination Manual provides valuable insight BSA Officers can use to strengthen their compliance programs.
For BSA exam preparation, use the manual to review how your risk assessment, policies, procedures, and controls address your risks.
While revisions do not automatically require a program rewrite, they do present an opportunity to assess whether your current approach remains appropriate and documented.
What has changed in the FFIEC examination manual?
The FFIEC has revised the exam manual several times since 2020, with updates in 2021, 2023, and 2026. The changes have addressed different topics, but they continue to emphasize a risk-based approach, transparency in examinations, and controls that reflect each individual risk profile.
The revisions consistently emphasize that customer due diligence should be commensurate with each institution’s risk profile and that financial institutions should not engage in unnecessary de-risking solely because a customer belongs to a traditionally higher-risk category.
The 2021 updates clarified examiner expectations for areas including charities and nonprofit organizations, politically exposed persons, and independent ATM owners and operators. The 2023 revisions reorganized several sections, including those related to foreign correspondent banking, private banking, foreign shell banks, information sharing, and Iranian-linked financial institutions.
The 2026 revisions removed references to reputational risk from several examination sections, including Suspicious Activity Reporting and Electronic Banking. While this change generated industry discussion, it did not lessen expectations for AML/CFT compliance. Instead, it reinforced the view that examinations should remain focused on identifying and mitigating money laundering, terrorist financing, and other illicit finance risks, rather than evaluating institutions based on broader reputational considerations.
