Removing Barriers Blog

FFIEC Updates BSA/AML Examination Manual
Posted June 21, 2021 by CUNA Advocacy

On Monday, the FFIEC announced an update to four parts of the BSA/AML Examination Manual’s section on Assessing the BSA/AML Compliance Program. The updated parts include International Transportation of Currency or Monetary Instruments Reporting, Purchase and Sale of Monetary Instruments Recordkeeping, Reports of Foreign Financial, and Special Measures. Of these, changes to Purchase and Sale of Monetary Instruments Recordkeeping would be of the most interest to credit unions. The changes do not establish new substantive requirements, as much as reorganized and recontextualize some of the previous text. The changes do remove provisions related to “Purchaser Verification” and “Acceptable Identification,” as other provisions in the BSA/AML rules now address these issues. The update does include new, more detailed information about examinations in this area, including that examiners should determine whether internal controls are designed to mitigate and manage money-laundering and terrorist financing risk and consideration of more general internal controls concepts, like segregation of duties and an appropriate approval process for the purchase and sale of certain monetary instruments. The new language also states that examiners should view limited instances of noncompliance or minor deviations from policy in the context of all examination findings and the credit union’s risk profile, rather treating these as necessarily resulting in an overall failure of internal controls.