John Zasada, Compliance Consulting Director, Financial Institutions Group

On Dec. 1, 2021, the Federal Financial Institutions Examination Council (FFIEC) released updates to three sections of the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual and added one new section. The updates impact the following four sections:

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

The new section on customers, which is only two pages, states examiners are reminded that no specific customer type automatically presents a higher risk of money laundering or terrorist financing or other illicit financial activity. In addition, the FFIEC encourages banks to manage customer relationships and mitigate risks based on those customer relationships rather than declining to provide banking services to entire categories of customers.

Importantly, the FFIEC emphasizes the updates should not be interpreted as new requirements, or as a new or increased focus on certain areas.

To learn more about this, please contact Doeren Mayhew’s regulatory compliance specialists.