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#2195786 - 10/18/18 12:25 PM 2018 Version of BSA/AML Exam Manual
Adam Witmer Offline
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https://bsaaml.ffiec.gov/

It took me a minute to see it, but it appears the 2018 version of the BSA Exam manual is up. The website is completely redone.
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#2195787 - 10/18/18 12:42 PM Re: 2018 Version of BSA/AML Exam Manual Adam Witmer
Adam Witmer Offline
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The website is completely redone (and I'm not sure I like it). The full PDF still appears to be the 2014 version (v.2), though the online portion lists updates from 2018, such as CDD and Beneficial Ownership.

To access the online version of the manual, go to: https://bsaaml.ffiec.gov/manual

The tabs on the left are how you navigate the online version. Upon a quick review, it seems that the only updates (so far) for 2018 relate to two sections: CDD & Beneficial Ownership.
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#2195789 - 10/18/18 01:06 PM Re: 2018 Version of BSA/AML Exam Manual Adam Witmer
Elwood P. Dowd Offline
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The pdf document indicates it is the 2014 version. There's a regulatory panel at the FBA's BSA-AML School tomorrow. I'll ask if they have any projected publication dates, but the last I heard was 2019.
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#2195925 - 10/19/18 11:01 AM Re: 2018 Version of BSA/AML Exam Manual Elwood P. Dowd
Adam Witmer Offline
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Originally Posted By Elwood P. Dowd
There's a regulatory panel at the FBA's BSA-AML School tomorrow. I'll ask if they have any projected publication dates, but the last I heard was 2019.

I'll be interested to hear what they say, Ken. Thanks for doing that.
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#2195980 - 10/19/18 05:08 PM Re: 2018 Version of BSA/AML Exam Manual Adam Witmer
Elwood P. Dowd Offline
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Per the panelist actually involved in the process, 2019 is the "hopeful" publication date.

Apparently, the manual is not just being "updated," It is being rewritten to make it more clear that it is mere "guidance," not a recitation of regulatory requirements. Another panelist commented that if the manual cannot be drafted so its status as guidance is clear, it might have to be put out for public comment before being published in final form.
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#2195989 - 10/19/18 06:26 PM Re: 2018 Version of BSA/AML Exam Manual Adam Witmer
Adam Witmer Offline
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Thanks for doing that, Ken. Very interesting information, but really not too surprising with the consistent guidance vs regulation focus the agencies have recently had. Either way, the good news is that BSA Officers have plenty to look forward to. wink
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Adam Witmer, CRCM

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#2196041 - 10/22/18 12:07 PM Re: 2018 Version of BSA/AML Exam Manual Elwood P. Dowd
edAudit Offline
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Originally Posted By Elwood P. Dowd
Per the panelist actually involved in the process, 2019 is the "hopeful" publication date.

Apparently, the manual is not just being "updated," It is being rewritten to make it more clear that it is mere "guidance," not a recitation of regulatory requirements. Another panelist commented that if the manual cannot be drafted so its status as guidance is clear, it might have to be put out for public comment before being published in final form.


I would rather that they cite the manual than make things up based upon a flawed interpretation of the regulation.
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#2196043 - 10/22/18 01:05 PM Re: 2018 Version of BSA/AML Exam Manual edAudit
Adam Witmer Offline
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Originally Posted By edAudit
Originally Posted By Elwood P. Dowd
Per the panelist actually involved in the process, 2019 is the "hopeful" publication date.

Apparently, the manual is not just being "updated," It is being rewritten to make it more clear that it is mere "guidance," not a recitation of regulatory requirements. Another panelist commented that if the manual cannot be drafted so its status as guidance is clear, it might have to be put out for public comment before being published in final form.


I would rather that they cite the manual than make things up based upon a flawed interpretation of the regulation.

My guess - and it only is that - is that the regulators are trying to move away from relying on the exam manual as having the final say, and turn toward FinCEN's Regulation X. I'm not sure why the Exam Manual has been the industry standard for years, but we should be relying on the actual regulation (when applicable). The newly redesigned website now has a good link to Regulation (Chapter) X (and other applicable BSA/AML rules), under the "Resources" tab and found here: https://bsaaml.ffiec.gov/references/regulations
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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