FFIEC Manual Updates – Summary and Impact

Updated: Jun 19


On Friday, May 29th and Wednesday, June 17th, the New York ACAMS Chapter hosted two identical virtual panel discussions titled FFIEC Manual Updates – Summary and Impact. About 1,000 people combined attended the two events. The discussion was moderated by New York ACAMS Chapter Board Committee Member, Kelly Cooper, and included the following subject matter experts:  Sarah Beth Felix (President at Palmera Consulting); Elsa de la Garza (Regulatory Compliance Specialist focusing on BSA and Consumer Compliance, and former OCC Bank Examiner); and Susan Galli (President at Galli AML Advisory LLC). The panelists discussed the importance of the recent FFIEC Manual updates in the context of the FATF’s methodology for reviewing effectiveness and the 2020 Illicit Finance Strategy released by the US Department of Treasury. The discussion included the impact that the updates have on the private sector, how the updates align to private sector expectations for revisions to the document, and the training process for examiners.  Key takeaways included clarifications between laws/regulations and guidance and important updates made to the guidance on risk assessments, which may impact the way in which risks are reviewed and how effectiveness is assessed. Participants were encouraged to read the referenced FATF and US Department of Treasury documents to fully understand the importance and context of the updates to the FFIEC Manual, and were reminded that changes to the FFIEC Manual don’t exempt an institution from identifying threats as outlined in the 2020 Illicit Finance Strategy.


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