Joint Trades Letter on the FFIEC AML Exam Manual and AML Reform Efforts

Board of Governors of the Federal Reserve System
20th Street & Constitution Ave NW
Washington, DC 20551

Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429

Office of the Comptroller of the Currency
400 7th Street SW
Washington, DC 20219

Financial Crimes Enforcement Network
P.O. Box 39
Vienna, VA 22183

Ladies and Gentlemen:

The Bank Policy Institute ("BPI"), American Bankers Association, Consumer Bankers Association, Independent Community Bankers of America, Institute of Internal Bankers, and the Securities Industry and Financial Markets Association (collectively, the "Associations") appreciate the recent release of revised sections of the Federal Financial Institutions Examination Council's ("FFIEC") Bank Secrecy Act/Anti-Money Laundering ("BSA/AML") Examination Manual ("Manual") and welcome the FFIEC's efforts to "emphasize and enhance the Agencies' risk-focused approach to BSA/AML supervision." These efforts are particularly timely as financial institutions work to prudently meet consumer and business economic needs and also assess their unique risks and available resources, in light of COVID-19 and related operational constraints, to prioritize high value anti-money laundering and combating the financing of terrorism ("AML/CFT") activities. 

Download the comment letter to read the full text.