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Financial Institution Letter

Bank Secrecy Act/Anti-Money Laundering Examination Manual Update


The Federal Financial Institutions Examination Council (FFIEC) is updating sections and related examination procedures in the FFIEC Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual.


  • The FFIEC BSA/AML Examination Manual (“Manual”) provides instruction to examiners for assessing a bank’s BSA/AML compliance program and its compliance with other BSA regulatory requirements.
  • The Manual sections updated are: (1) Introduction – Customers; (2) Charities and Nonprofit Organizations; (3) Independent Automated Teller Machines Owners or Operators; and (4) Politically Exposed Persons.
  • The sections remind examiners that no specific customer type automatically presents a higher risk of money laundering, terrorist financing, or other illicit financial activity.
  • 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.
  • The Manual itself does not establish requirements for financial institutions; such requirements are found in statutes and regulations.
  • Financial institutions should not interpret the updates as new instructions or an increased focus on certain areas; instead, the updates are intended to offer further transparency into the examination process and support risk-focused examination work.
  • New and revised Manual sections are identified by a 2021 date on the FFIEC BSA/AML InfoBase.
  • Future updates to other Manual sections will be announced as they are completed.


FDIC-Supervised Institutions

Last Updated: December 1, 2021