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 bankâ€™s risk profile."