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FIL-56-2005 Attachment
Board of Governors of the Federal Reserve System
Federal Deposit Insurance Corporation
National Credit Union Administration
Office of the Comptroller of the Currency
Office of Thrift Supervision
Financial Crimes Enforcement Network


June 30, 2005

To Each Banking Organization Supervised by the Federal Banking Agencies

Subject: Federal Financial Institutions Examination Council Bank Secrecy Act/Anti-Money Laundering Examination Manual

The Federal Financial Institutions Examination Council issued today the Bank Secrecy Act /Anti-Money Laundering (BSA/AML) Examination Manual (Manual). 1 The Manual is the result of a collaborative effort of the federal banking agencies 2 and the Financial Crimes Enforcement Network (FinCEN), to ensure consistency in BSA/AML examinations. The Manual includes the examination procedures that examiners will begin using during the third quarter of 2005 when conducting BSA/AML examinations of banking organizations. 3

The Manual reinforces the agencies' position that sound BSA/AML risk management enables a banking organization to identify BSA/AML risks and better direct its resources, with the ultimate goal of safeguarding its operations from money laundering or terrorist financing. The Manual does not set new standards; instead, it is a compilation of existing regulatory requirements, supervisory expectations, and sound practices in the BSA/AML area. In fact, while the document is approximately 300 pages in length, more than two-thirds of it is dedicated to providing narrative guidance and resource materials. Compliance and business line personnel should review this Manual carefully to ensure that your banking organization is properly addressing BSA/AML compliance and risk management issues.

The guidance and procedures contained within the Manual will assist examiners, as well as banking organizations, in understanding relevant laws and regulations. To this end, the Manual provides the following:

  • An overview of BSA/AML and Office of Foreign Assets Control compliance obligations placed on banking organizations,
  • Supervisory expectations in this area, and
  • Guidance on identifying and controlling risks.

The federal banking agencies and FinCEN have planned a series of nationwide conference calls and regional outreach meetings to assist banking organizations in further understanding the Manual. More information, including logistics and registration, is being distributed separately. 4

The Manual will be reviewed and updated as necessary as new regulations and guidance are issued, technology advances, and money laundering and terrorist financing risks evolve. For more information, please contact the local office of your federal banking agency.

_________________________________
Susan Schmidt Bies,Governor
Board of Governors of the Federal
Reserve System
_________________________________
Julie L. Williams, Acting Comptroller
Office of the Comptroller of the Currency
_________________________________
Donald E. Powell, Chairman
Federal Deposit Insurance Corporation
_________________________________
Richard M. Riccobono, Acting Director
Office of Thrift Supervision
_________________________________
JoAnn Johnson, Chairman
National Credit Union Administration
_________________________________
William J. Fox, Director
Financial Crimes Enforcement Network



1 The Manual can be found at:
FFIEC BSA/AML Examination Manual Introduction – Overview – PDF 621k ( PDF Help )
FFIEC BSA/AML Examination Manual Examination Procedures – PDF 451k ( PDF Help )
FFIEC BSA/AML Examination Manual Appendixes – PDF 216k ( PDF Help )

2 The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, Office of the Comptroller of the Currency, and Office of Thrift Supervision. In addition, through the Conference of State Bank Supervisors, the state banking agencies played a consultative role.

3 The term “banking organization” used throughout this letter includes commercial banks, savings associations, and credit unions.

4 The national conference calls and regional outreach events will be conducted by the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, Office of Thrift Supervision, and FinCEN.