On August 2, the Federal Financial Institutions Examination Council (FFIEC) announced updates to certain sections and examination procedures in the FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual (Manual). The Manual instructs examiners on how to assess a bank’s anti-money laundering/countering the financing of terrorism (AML/CFT) program and its compliance with other AML/CFT regulatory requirements. The FFIEC cautions that the updates should not be seen as new instructions or an increased focus on certain areas, but instead as offering further transparency into the examination process and supporting risk-focused examination work.
Manual updates are located within the Assessing Compliance with Bank Secrecy Act 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. Revised Manual sections are identified by a 2023 date on the FFIEC BSA/AML Infobase.