Mon, Dec 15, 2014
A revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) examination manual was unveiled December 3 by the Federal Financial Institutions Examination Council (FFIEC).
The updates clarify supervisory expectations regarding compliance and incorporate regulatory changes since the manual was last updated in 2010.
The revision was conducted by the National Credit Union Administration, along with the Federal Reserve Board, Federal Deposit Insurance Corp., Office of the Comptroller of the Currency and the State Liaison Committee--all members of the FFIEC. The Financial Crimes Enforcement Network (FinCEN), BSA administrator and Office of Foreign Assets Control collaborated on the revisions, which incorporated comments from the financial services industry and examination staff.
Some of the significant revisions include:
- New suspicious activity report (SAR) e-filing requirements, guidance on the extension of SAR filing for continuing activity, clarification of prohibitions on disclosing a SAR and guidance on sharing SARs with affiliates;
- Currency transaction reporting (CTR): Revised to incorporate new CTR e-filing requirements and new guidance issued by FinCEN since 2010 related to currency transaction aggregation for businesses and exemptions;
- Clarified monitoring and reporting obligations under the BSA for international transportation of currency or monetary instruments;
- Incorporated NACHA, the Electronic Payments Association modifications related to international automated clearing house transactions and further defined third-party service providers;
- Replaced electronic cash section and included an expanded discussion of risk factors and risk mitigation related to prepaid access; and
- Incorporated new FinCEN regulations for money services businesses (MSB) related to certain foreign-located persons engaging in MSB activities; new regulations related to prepaid access programs; and guidance regarding virtual currency administrators and exchangers.
According to the FFIEC, credit unions should direct questions about the revisions to the NCUA. The online version of the Manual is available in PDF format.