BSA/AML Manual Updates

On August 2, 2023, the FFIEC released updates to its Bank Secrecy Act/Anti-Money Laundering Examination Manual. The following sections were revised:

• Special Information Sharing Procedures to Deter Money Laundering and Terrorist Activity
• Due Diligence Programs for Correspondent Accounts for Foreign Financial Institutions
• Due Diligence Programs for Private Banking Accounts

The following sections were added:

• Prohibition on Correspondent Accounts for Foreign Shell Banks; Records Concerning Owners of Foreign Banks and Agents for Service of Legal Process
• Summons or Subpoena of Foreign Bank Records; Termination of Correspondent Relationship; Records Concerning Owners of Foreign Banks and Agents for Service of Legal Process
• Reporting Obligations on Foreign Bank Relationships with Iranian-Linked Financial Institutions

The changes are relatively minor and mainly a reorganization of sorts to help align the guidance better with the corresponding regulations. As you can see, many of the affected sections are related to more specialized products/services like Private Banking, Foreign Banking, etc.; however, there are some that affect many banks. For example, the “Special Information Sharing Procedures to Deter Money Laundering and Terrorist Activity” section addresses 314(a) and 314(b) information sharing.

Please note these updates do not change any existing regulatory requirements or impose any new requirements on financial institutions.

Published
2023/08/11