FDIC has revised its BSA/AML exam manual according to a 4/15/2020 FIL. They claim, of course, that the updates do not represent increased compliance burden or pose significant changes. That said, has anyone had time to review it in-depth, and have you noticed any significant changes?

Reference: FIL 44-2020; attachments include the entire exam manual, plus a 2-page summary of the changes.

This one is interesting. I always thought the BSA/AML Risk Assessment had to be updated annually, but now we see this in the summary:

"The Manual also instructs examiners that there is no requirement for risk assessment updates on a continuous or specified periodic basis, but these updates may occur as necessary to align the risk assessment with a significant change in a bank’s risk profile."

yeah - perfect timing.. like... seriously? now is the time to do that? oh hey HMDA got finalized too!!! Perfect timing for us to sit and spend hours reading...

jesus christ....

The exam manual in the FDIC FIL is the 43 page update. It is NOT the entire manual.

I had already had an examiner tell me that an annual BSA risk assessment wasn't required that it should be risk based. That was before this was published.

Op here.



Oh, gee. I hadn't noticed that. Yuck. How do we get this thing into quarantine, fast? We need to stop this before it spreads.