The Federal Financial Institutions Examination Council (FFIEC) periodically updates its BSA Examination Manual, with the most recent update on December 1, 2021. This release is the latest since revisions began in 2020 as the council attempts to clarify and achieve transparency within sections of this valuable resource. The manual is used by examiners as a training tool and guide when performing bank examinations. It is also the go-to source for AML professionals seeking regulatory expectations for BSA programs across the financial services industry.
The December 2021 updates affect four sections of the existing examination manual, each discussed below. None of the changes represent new information but rather address specific customers that may need more attention within policies, procedures, and processes due to a higher risk for money laundering, terrorist financing, and other illicit activity. Each customer category has long been named in the exam manual as having elevated risk. The updates also clarify examiner expectations in these customer categories.