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April 17, 2020
Christian Larson comments on the Federal Financial Institutions Examination Council’s recent updates to the BSA/AML Examination Manual, reminding examiners that banks have flexibility in designing their BSA/AML compliance programs.
An excerpt from “Bank Regulators Urge ‘Risk-Based’ Approach To AML Exams,” Law360, April 17, 2020:
Christian Larson, an anti-money laundering attorney with Cadwalader Wickersham & Taft LLP, agreed that the updates do a good job clarifying the differences between regulatory requirements and supervisory expectations.
However, he cautioned that banks should take the “new requirements” comment with a grain of salt, noting that banks should work to comply both with requirements as well as supervisory expectations.
“Some banks are ‘A students’ in the sense that their legal and compliance departments carefully track new regulations and supervisory guidance as they are issued,” Larson said. “Other banks use the FFIEC manual as a ‘CliffsNotes’ for BSA/AML compliance.”
“For banks in the latter category, it may be time to study up,” he said.