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FFIEC Issues New BSA/AML Exam Manual
Friday, February 27, 2015 6:30 AM


In December, federal banking regulators provided advice for safeguarding against money laundering and terrorist financing.

In the 2014 Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual, the Federal Financial Institutions Examination Council (FFIEC) revised guidance on risk-based policies, procedures, and processes for financial institutions.

Although the regulators made revisions throughout the manual, significant updates included the following topics:

  • Suspicious Activity Reporting (SAR): incorporated new SAR e-filing requirements; guidance on the extension of SAR filing for continuing activity; clarification of prohibitions on disclosing a SAR; and guidance on sharing SARs with affiliates.
  • Currency Transaction Reporting (CTR): revised to incorporate new CTR e-filing requirements and new guidance issued by FinCEN since 2010 related to currency transaction aggregation for businesses and exemptions.
  • International Transportation of Currency or Monetary Instruments Reporting: clarified monitoring and reporting obligations under the BSA for international transportation of currency or monetary instruments.
  • Automated Clearing House transactions (ACH): incorporated National Automated Clearing House Association (NACHA) and The Electronic Payments Association modifications related to international ACH transactions, and further defined third-party service providers.
  • Prepaid access: replaced "electronic cash" section and included an expanded discussion of risk factors and risk mitigation related to prepaid access.
  • Third-party payment processors: made updates reflecting interagency guidance issued since 2010.
  • Nonbank financial institutions: incorporated new Financial Crimes Enforcement Network (FinCEN) regulations for money services businesses (MSBs) related to "certain foreign-located persons" engaging in MSB activities; new regulations related to prepaid access programs; and guidance regarding virtual currency administrators and exchangers.
  • Appendix T: BSA e-filing system: created to provide examiners with information on the FinCEN BSA e-filing system.

The NCUA, FDIC, Office of the Comptroller of the Currency, Federal Reserve Board, and State Liaison Committee updated the manual in collaboration with the Financial Crimes Enforcement Network and the Office of Foreign Assets Control.

Find the manual on the FFIEC BSA/AML InfoBase at