Board of Governors of the Federal Reserve System

Members of the Federal Financial Institutions Examination Council (FFIEC)¹ released a new section and updated three sections with related examination procedures to the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual (Manual). The Manual provides instructions to examiners when assessing the adequacy of a bank's BSA/AML compliance program, relative to its risk profile, and the bank's compliance with BSA regulatory requirements. These sections provide further transparency into the BSA/AML examination process and do not establish new requirements. The FFIEC drafted and revised the sections in close collaboration with the U.S. Treasury Department's Financial Crimes Enforcement Network (FinCEN). The sections included in this release are:

• Introduction – Customers (New Section)
• Charities and Nonprofit Organizations
• Independent Automated Teller Machine Owners or Operators
• Politically Exposed Persons

These sections provide information and considerations related to certain customers that may indicate the need for bank policies, procedures, and processes to address potential money laundering, terrorist financing, and other illicit financial activity risks. The updates are based on concepts conveyed in the previously issued Joint Statement on Bank Secrecy Act Due Diligence Requirements for Customers Who May Be Considered Politically Exposed Persons² and Joint Fact Sheet on Bank Secrecy Act Due Diligence Requirements for Charities and Non-Profit Organizations.³ These interagency statements make clear that no specific customer type automatically presents a higher money laundering, terrorist financing risk. They further state that banks that operate in compliance with applicable BSA/AML requirements and reasonably manage and mitigate risks related to the unique characteristics of the customer relationship are neither prohibited nor discouraged from providing banking services to any specific class or type of customer.

The revisions to the Manual continue to emphasize the agencies' risk-focused approach to BSA/AML supervision and reinforce the distinction between regulatory requirements and considerations set forth in guidance. Further, the revisions incorporate regulatory requirements and other changes, as applicable.

Revised sections of the Manual are attached and will be identified by a 2021 date on the FFIEC BSA/AML InfoBase.⁴ The agencies will continue to review and revise the remaining sections of the 2014 edition of the Manual and release updates as they are completed. Previous updates include those from April 2020, February 2021, and June 2021. All Manual updates are catalogued on the FFIEC BSA/AML InfoBase under the “What's New” page.

This SR Letter supersedes SR 21-9, “Release of Updated Sections of the Federal Financial Institutions Examination Council's Bank Secrecy Act/Anti-Money Laundering Examination Manual.”

Reserve Banks are asked to distribute this letter to the supervised banking organizations in their districts and to appropriate supervisory staff. Questions regarding this letter may be sent via the Board's public website.⁵

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