Blog: AML / BSA

Most bankers encounter the FFIEC BSA/AML Examination Manual indirectly: an examiner cites it, a consultant references it, or a vendor's training mentions it. Comparatively few have read the sections that apply to their own institution, which is a missed opportunity — it is the closest thing available to the examiner's own working document.

What the Manual Is, and Is Not

The manual is issued by the Federal Financial Institutions Examination Council and provides examination

The last several years have been the most active period of AML rulemaking since the USA PATRIOT Act, and unusually for compliance topics, much of it has not settled. Rules have been finalized, challenged in court, narrowed by interim rules, and had compliance dates moved.

This post covers the developments a bank compliance function needs to be tracking, what each one means operationally, and — importantly — which of them are still in motion.

The Legislative