10 Hot BSA Exam Issues
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The FFIEC members have added a new introductory section and revised content in the Customer Identification Program, Currency Transaction Reporting, and Transactions of Exempt Persons. The Manual provides instructions to examiners for assessing the adequacy of a bank’s BSA/AML compliance program and its compliance with BSA regulatory requirements. The Manual itself does not establish requirements for banks; such requirements are found in statutes and regulations. The updates should not be interpreted as new instructions or as a new or increased focus on certain areas; instead, they offer further transparency into the examination process and support risk-focused examination work. The FFIEC revised the sections in close collaboration with Treasury’s Financial Crimes Enforcement Network.