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#2195786 - 10/18/18 12:25 PM
2018 Version of BSA/AML Exam Manual
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Joined: Sep 2010
Posts: 2,658
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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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Adam Witmer, CRCM All statements are my opinion, not those of my employer, and should not be taken as legal advice. www.compliancecohort.com
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#2195787 - 10/18/18 12:42 PM
Re: 2018 Version of BSA/AML Exam Manual
Adam Witmer
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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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Adam Witmer, CRCM All statements are my opinion, not those of my employer, and should not be taken as legal advice. www.compliancecohort.com
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#2195789 - 10/18/18 01:06 PM
Re: 2018 Version of BSA/AML Exam Manual
Adam Witmer
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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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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#2195925 - 10/19/18 11:01 AM
Re: 2018 Version of BSA/AML Exam Manual
Elwood P. Dowd
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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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Adam Witmer, CRCM All statements are my opinion, not those of my employer, and should not be taken as legal advice. www.compliancecohort.com
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#2195980 - 10/19/18 05:08 PM
Re: 2018 Version of BSA/AML Exam Manual
Adam Witmer
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Posts: 21,939
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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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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#2195989 - 10/19/18 06:26 PM
Re: 2018 Version of BSA/AML Exam Manual
Adam Witmer
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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.
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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. www.compliancecohort.com
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#2196041 - 10/22/18 12:07 PM
Re: 2018 Version of BSA/AML Exam Manual
Elwood P. Dowd
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Joined: Jul 2008
Posts: 4,796
You are here
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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. 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
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Joined: Sep 2010
Posts: 2,658
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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. 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. www.compliancecohort.com
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