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Financial Institution Letter

Bank Secrecy Act/Anti-Money Laundering Examination Manual Update

August 2, 2023  |  FIL-40-2023

Summary:

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.

Statement of Applicability: The contents of, and material referenced in, this FIL apply to all FDIC-supervised financial institutions.

Highlights:

  • The FFIEC BSA/AML Examination Manual (Manual) provides instruction to examiners for assessing a bank’s anti-money laundering/countering the financing of terrorism (AML/CFT) program and its compliance with other AML/CFT regulatory requirements.
  • Manual updates are located within the Assessing Compliance with BSA Regulatory Requirements section and include:  (1) Due Diligence Programs for Correspondent Accounts for Foreign Financial Institutions (2) Prohibition on Correspondent Accounts for Foreign Shell Banks; Records Concerning Owners of Foreign Banks and Agents for Service of Legal Process (3) Reporting Obligations on Foreign Bank Relationships with Iranian-Linked Financial Institutions (4) Summons or Subpoena of Foreign Bank Records; Termination of a Correspondent Relationship; Records Concerning Owners of Foreign Banks and Agents for Service of Legal Process (5) Due Diligence Programs for Private Banking Accounts and (6) Special Information Sharing Procedures to Deter Money Laundering and Terrorist Activity.
  • The Manual itself does not establish requirements for financial institutions; such requirements are found in the 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 2023 date on the FFIEC BSA/AML Infobase.
  • Future updates to other Manual sections will be announced as they are completed.

Related Topic:

Bank Secrecy Act