Unknown Sponsor Bank
On December 1, 2021, the FFIEC (involving FinCEN and other federal banking agencies) published the third update of 2021 to the BSA/AML Examination Manual. The update introduced new examiner evaluation criteria covering risks associated with charities and non-profit organizations, politically exposed persons (PEPs), and independent ATM operators. It focused on customer due diligence, beneficial ownership, and suspicious activity reporting, while explicitly not imposing new regulatory requirements. For BaaS providers and sponsor banks, the updated examination manual is significant because examiners will apply these enhanced evaluation criteria during BSA/AML examinations, particularly relevant for banks serving diverse fintech partners with varied customer bases.
Verified from source: On December 1, 2021, the FFIEC released its third 2021 update to the BSA/AML Examination Manual, adding a new introductory section on customers and updating sections pertaining to Charities and Nonprofit Organizations, Independent ATM Owners or Operators, and Politically Exposed Persons, including new examiner evaluation subsections.
- BaaS sponsor banks should review updated BSA/AML examination criteria for compliance readiness
- Enhanced examiner focus on CDD, beneficial ownership, and SAR filing affects banks with high-volume fintech partnerships
- No new requirements imposed, but examination standards effectively raise the compliance bar