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OCC Bulletin 2023-26 | August 2, 2023

Bank Secrecy Act/Anti-Money Laundering: Updated Sections of the FFIEC BSA/AML Examination Manual

To

Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties

Summary

The Federal Financial Institutions Examination Council (FFIEC) updated the following sections of the FFIEC Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual :

  • “Special Information Sharing Procedures to Deter Money Laundering and Terrorist Activity”
  • “Due Diligence Programs for Correspondent Accounts for Foreign Financial Institutions”
  • “Due Diligence Programs for Private Banking Accounts”
  • “Prohibition on Correspondent Accounts for Foreign Shell Banks; Records Concerning Owners of Foreign Banks and Agents for Services of Legal Process”
  • “Summons or Subpoena of Foreign Bank Records; Termination of Correspondent Relationship; Records Concerning Owners of Foreign Banks and Agents for Service of Legal Process”
  • “Reporting Obligations on Foreign Bank Relationships With Iranian-Linked Financial Institutions”

These updates reflect the Office of the Comptroller of the Currency’s continued commitment to, and leadership on, interagency reform efforts that improve the effectiveness and efficiency of the BSA/AML regime and reduce unnecessary burden on banks.1

Note for Community Banks

The updated FFIEC BSA/AML Examination Manual applies to the supervision of community banks.

Highlights

The updated sections reinforce the risk-focused approach to BSA/AML examinations. Specifically, the updates are as follows:

  • “Special Information Sharing Procedures to Deter Money Laundering and Terrorist Activity”
    • Updated and retitled the previous “Information Sharing” section to align with the regulations at 31 CFR 1010.520 and 31 CFR 1010.540.
  • “Due Diligence Programs for Correspondent Accounts for Foreign Financial Institutions”
    • Updated and combined the previous “Foreign Correspondent Account Recordkeeping, Reporting, and Due Diligence” and “Correspondent Accounts (Foreign)” sections and retitled to align with the regulation at 31 CFR 1010.610.
  • “Due Diligence Programs for Private Banking Accounts”
    • Updated and combined the previous “Private Banking Due Diligence Program (Non-US Persons)” and “Private Banking” sections and retitled to align with the regulation at 31 CFR 1010.620.
  • “Prohibition on Correspondent Accounts for Foreign Shell Banks; Records Concerning Owners of Foreign Banks and Agents for Service of Legal Process”
    • Created a new stand-alone section from the previous “Foreign Correspondent Account Recordkeeping, Reporting, and Due Diligence” section and titled it to align with the regulation at 31 CFR 1010.630.
  • “Summons or Subpoena of Foreign Bank Records; Termination of Correspondent Relationship; Records Concerning Owners of Foreign Banks and Agents for Service of Legal Process”
    • Created a new stand-alone section from the previous “Foreign Correspondent Account Recordkeeping, Reporting, and Due Diligence” section and titled it to align with the regulation at 31 CFR 1010.670 and 31 CFR 1010.630.
  • “Reporting Obligations on Foreign Bank Relationships With Iranian-Linked Financial Institutions”
    • Created new stand-alone section from the previous “Foreign Correspondent Account Recordkeeping, Reporting, and Due Diligence” section and titled it to align with the regulation at 31 CFR 1060.300.

Further Information

Please contact Eric Ellis, Director, BSA Policy, at (202) 649-5470.

Grovetta N. Gardineer
Senior Deputy Comptroller for Bank Supervision Policy

1 "Banks" collectively refers to national banks, federal savings associations, and federal branches and agencies of foreign banking organizations.