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The Federal Financial Institutions Examination Council (FFIEC), which includes the NCUA, Wednesday released an update to its Bank Secrecy Act (BSA)/anti-money laundering (AML) examination manual. These updates have been in the works and are not in response to the coronavirus pandemic.

In an interagency statement, the financial regulators noted that "[m]any of the revisions are designed to emphasize and enhance the Agencies' risk-focused approach to BSA/AML supervision." Significant revisions include providing instructions to examiners on:

• risk-focused BSA/AML supervision, specifically for tailoring BSA/AML examinations to a credit union's risk profile, including examination and testing procedures, and conducting risk-focused testing or analytical reviews;
• assessing the adequacy of a BSA/AML compliance program by constituting a minimum set of procedures for full scope BSA/AML examinations and separating internal controls, independent testing, BSA compliance officer, and training into individual sections;
• BSA/AML risk assessment, especially for assessing the adequacy of a credit union's BSA/AML risk assessment processes, by identifying specific risk categories unique to the credit union and analyzing the information identified to better asses risk within these categories;
• developing conclusions and finalizing the exam as it reminds examiners that credit unions have flexibility in the design of their BSA/AML compliance programs, and minor weaknesses, deficiencies and technical violations alone are not indicative of an inadequate program.

Access the updated manual here.

While this updated manual does not specifically address coronavirus concerns, the Financial Crimes Enforcement Network has provided some relief related to currency transaction reports and previously encouraged financial institutions to contact the agency and the institution's respective regulator with concerns about filing required BSA reports amid the pandemic.