Bank Secrecy Act/ Anti-Money Laundering Examination Manual (AML) :Examination Procedures: Narrative Guidance and Background Information

This Federal Financial Institutions Examination Council (FFIEC) Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) Examination Manual provides guidance to examiners for carrying out BSA/AML and Office of Foreign Assets Control (OFAC) examinations. An effective BSA/AML compliance program requires sound risk management; therefore, the manual also provides guidance on identifying and controlling risks associated with money laundering and terrorist financing. The manual contains an overview of BSA/AML compliance program requirements, BSA/AML risks and risk management expectations, industry sound practices, and examination procedures. The development of this manual was a collaborative effort of the federal and state banking agencies1 and the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, to ensure consistency in the application of the BSA/AML requirements. In addition, OFAC assisted in the development of the sections of the manual that relate to OFAC reviews. For more guidance, refer to Appendix A (“BSA Laws and Regulations”), Appendix B (“BSA/AML Directives”), and Appendix C (“BSA/AML References”).
Structure of Manual
In order to effectively apply resources and ensure compliance with BSA requirements, the manual is structured to allow examiners to tailor the BSA/AML examination scope and procedures to the specific risk profile of the banking organization. The manual consists of the following sections:
• Introduction.
• Core Examination Overview and Procedures for Assessing the BSA/AML Compliance Program.
• Core Examination Overview and Procedures for Regulatory Requirements and Related Topics.
• Expanded Examination Overview and Procedures for Consolidated and Other Types of BSA/AML Compliance Program Structures.
• Expanded Examination Overview and Procedures for Products and Services.
• Expanded Examination Overview and Procedures for Persons and Entities.
• Appendixes.
The core and expanded overview sections provide narrative guidance and background information on each topic; each overview is followed by examination procedures.