Isn't it ironic that the revised Bank Secrecy Act/Anti-Money Laundering manual is released just one week before the newest version of the movie Halloween comes out. Makes you wonder doesn't it, because horror, like beauty is subjective and all in the mind of the beholder. But, on to more serious matters.
The FFIEC has released the 2007 version of the BSA/AML Examination Manual and it's ONLY 405 pages. The FFIEC also release a letter highlighting the changes to the manual. While I have not yet reviewed the manual in detail, below is a list of the changes outlined in the FFIEC letter.
Customer Due Diligence - Clarified regulatory expectations between lower-risk and higher-risk customers.
Suspicious Activity Reporting - The discussion of law enforcement inquiries and requests has been enhanced. Updated the section to include new guidance on maintaining accounts and support documentation.
Foreign Correspondent Account Recordkeeping and Due Diligence - The agencies updated this section to reflect new enhanced due diligence requirements with respect to correspondent accounts established or maintained for certain foreign banks.
Office of Foreign Assets Control - Guidance on screening responsibilities in connection ACH transaction has been revised and clarified. Made corresponding changes to the ACH section.
Foreign Correspondent Accounts - Enhanced the risk mitigation discussion in connection with these accounts.
Electronic Banking - The manual includes a new discussion regarding the practice of remote deposit capture.
Trade Finance - Clarified explanation of regulatory expectations, refined definitions, and an enhanced discussion of risk mitigation practices.
Non-Bank Financial Institutions - The revisions expand the discussion on providing banking services to money service businesses.
Money Laundering and Terrorist Financing "Red Flags" - Appendix F is expanded to include more examples of red flags for trade finance, ACH transactions, shell company activity, and other potentially suspicious customer activity and added new examples for lending activity.
Enforcement Guidance - Modified Appendix R to reflect recent interagency enforcement guidance addressing noncompliance with BSA/AML requirements.
Two other items of note:
Table of Contents - has (2007) next to several topics. This let's us know they updated these pages.
Index - The agencies added a detailed, cross-referenced index featuring key terminology and subject matters, which appears to be helpful in navigating the manual.
The revised exam manual can be downloaded at the link below.
