The Federal Financial Institutions Examination Council (FFIEC) has made several updates to the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examiner’s Manual. CUNA’s compliance staff have detailed on CompBlog the changes, which are unrelated to the coronavirus disease (COVID-19) pandemic, nor do they include any new requirements.

The update is intended to provide more specific instructions to examiners for risk-focusing examinations, as well as instructions on how to assess a credit union’s compliance program, including internal controls, independent testing, BSA Officer qualifications & training.

It notes that credit unions should be prepared:

• To provide an adequate risk assessment, which generally involves the identification of specific risk categories (products, services, members, and geographic locations) unique to the credit union, and an analysis of the information identified to better assess the risks within these specific risk categories:
  • Include new products, services and member types, introduced since your last exam;
  • Include new products, services and member types added through mergers and acquisitions.
• To describe the credit union’s processes for updating your BSA/AML assessment as necessary to reflect changes in products, services, members and locations;
• To have more extensive testing in areas that have had significant changes in their business strategies, geographic locations, transaction activity, products, services, member types, operations, and/or technology since your previous exam;  
• To demonstrate how you document the BSA/AML risk assessment in writing to effectively communicate Money Laundering/Terrorist Financing (ML/TF) to appropriate credit union personnel, and to all business lines across the credit union, your Board of Directors, and management;
• To provide a written BSA/AML Compliance Program, tailored to the credit union’s unique risk-profile that includes internal controls, independent testing, the designation of a qualified BSA Officer, Member Identification Program, Customer Due Diligence and Beneficial Owner procedures.
• To have the same areas tested in successive examinations based on previous exam findings.

Additional details can be found on CUNA’s CompBlog.