On April 15, the Federal Financial Institutions Examination Council (‘FFIEC’) released several updated sections and related examination procedures to the Bank Secrecy Act/Anti-Money Laundering (‘BSA/AML’) Examination Manual (the ‘Manual’).

These updates provide instructions to examiners when assessing the adequacy of a bank’s BSA/AML compliance program relative to its risk profile for money laundering, terrorist financing, and other illicit financial activities. Although no new requirements were listed, the revisions reflect an increased and focused risk-based approach taken by examiners during their reviews. Banks that have had significant changes to the BSA/AML compliance processes since the previous BSA/AML examination may require more extensive testing.