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BOARD OF GOVERNORS

OF THE

FEDERAL RESERVE SYSTEM

WASHINGTON, D.C. 20551 

DIVISION OF SUPERVISION

AND REGULATION

SR 23-6 

August 2, 2023 

TO THE OFFICER IN CHARGE OF SUPERVISION AND APPROPRIATE 

SUPERVISORY AND EXAMINATION STAFF AT EACH FEDERAL RESERVE BANK 

AND BANKING ORGANIZATIONS SUPERVISED BY THE FEDERAL RESERVE

SUBJECT: Release of Six Sections of the Federal Financial Institutions Examination 

Council’s Bank Secrecy Act/Anti-Money Laundering Examination Manual

Applicability: This letter is relevant to banking organizations supervised by the Federal Reserve 

that are subject to the Bank Secrecy Act.

Members of the Federal Financial Institutions Examination Council (FFIEC)1 released

six sections of the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual 

(the Manual) including related examination procedures. The FFIEC drafted and revised the 

sections in close collaboration with the U.S. Treasury Department’s Financial Crimes 

Enforcement Network (FinCEN). This letter pertains to sections related to BSA regulatory 

requirements for information sharing, due diligence for correspondent accounts and private 

banking accounts, prohibition on correspondent accounts for foreign shell banks, law 

enforcement access to foreign bank records, and provisions relating to the comprehensive Iran 

sanctions. The updates do not establish new requirements and should not be interpreted as 

increased focus on certain areas; instead, they offer further transparency into the examination 

process and support risk-focused examination work. 

The Manual provides instructions to examiners for assessing the adequacy of a banking 

organization’s BSA/AML compliance program, relative to its risk profile, and the banking 

organization’s compliance with BSA regulatory requirements. The Manual continues to 

emphasize the member agencies’ (the agencies) risk-focused approach to BSA/AML supervision 

and does not establish new requirements. The revisions are intended to clarify and reinforce 

distinctions between regulatory requirements and considerations set forth in guidance. Consistent 

with the Joint Statement on the Risk-Based Approach to Assessing Customer Relationships and 

Conducting Customer Due Diligence,2 the sections were updated to emphasize that no customer 

1 Five of the six FFIEC member agencies develop and release the BSA/AML Examination Manual: the Federal 

Reserve Board (Federal Reserve), Federal Deposit Insurance Corporation (FDIC), National Credit Union 

Administration (NCUA), Office of the Comptroller of the Currency (OCC), and State Liaison Committee. The 

Consumer Financial Protection Bureau is also a voting member of the FFIEC.

2 See Joint Statement on the Risk-Based Approach to Assessing Customer Relationships and Conducting Customer 

Due Diligence (July 6, 2022).
 

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type presents a single level of uniform risk or a particular risk profile related to money 

laundering, terrorist financing, or other illicit financial activity. 

The agencies reorganized some existing sections of the Manual to create new, individual 

sections based on specific regulations. Updates to the six sections included in this release are 

detailed below. There were no changes to the regulatory requirements covered by these sections. 

Special Information Sharing Procedures to Deter Money Laundering and Terrorist 

Activity

• Updated and retitled the previous Information Sharing section to align with the 

regulations at 31 CFR 1010.520 and 31 CFR 1010.540. 

Due Diligence Programs for Correspondent Accounts for Foreign Financial Institutions

• Updated and combined the previous Foreign Correspondent Account 

Recordkeeping, Reporting and Due Diligence and Correspondent Accounts 

(Foreign) sections and retitled to align with the regulation at 31 CFR 1010.610. 

Due Diligence Programs for Private Banking Accounts

• Updated and combined the previous Private Banking Due Diligence Program 

(Non-US Persons) and Private Banking sections and retitled to align with the 

regulation at 31 CFR 1010.620. 

Prohibition on Correspondent Accounts for Foreign Shell Banks; Records Concerning 

Owners of Foreign Banks and Agents for Service of Legal Process

• Created a new stand-alone section from the previous Foreign Correspondent 

Account Recordkeeping, Reporting, and Due Diligence section and titled it to 

align with the regulation at 31 CFR 1010.630. 

Summons or Subpoena of Foreign Bank Records; Termination of Correspondent 

Relationship; Records Concerning Owners of Foreign Banks and Agents for Service of 

Legal Process 

• Created a new stand-alone section from the previous Foreign Correspondent 

Account Recordkeeping, Reporting, and Due Diligence section and titled it to 

align with the regulations at 31 CFR 1010.670 and 31 CFR 1010.630. 

Reporting Obligations on Foreign Bank Relationships with Iranian-Linked Financial 

Institutions

• Created a new stand-alone section from the previous Foreign Correspondent 

Account Recordkeeping, Reporting, and Due Diligence section and titled it to 

align with the regulation at 31 CFR 1060.300. 
 

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Revised sections of the Manual are attached and will be identified by a 2023 date on the 

FFIEC BSA/AML InfoBase3 within Assessing Compliance with BSA Regulatory Requirements

once it is updated. The agencies will continue to review and revise the Manual and release 

updates as they are completed. Previous updates include those from April 2020, February 2021, 

June 2021, and December 2021, which are catalogued on the FFIEC BSA/AML InfoBase under 

the “What’s New” page.

Reserve Banks are asked to distribute this letter to the supervised banking organizations 

in their districts and to appropriate supervisory staff. Questions regarding this letter may be sent 

via the Board’s public website.4

Michael S. Gibson

Director

Division of Supervision and Regulation 

Attachments:

• FFIEC Announcement, Updates to the FFIEC BSA/AML Examination Manual

• Special Information Sharing Procedures to Deter Money Laundering and Terrorist 

Activity

• Due Diligence Programs for Correspondent Accounts for Foreign Financial Institutions 

• Due Diligence Programs for Private Banking Accounts 

• Prohibition on Correspondent Accounts for Foreign Shell Banks; Records Concerning 

Owners of Foreign Banks and Agents for Service of Legal Process 

• Summons or Subpoena of Foreign Bank Records; Termination of Correspondent 

Relationship; Records Concerning Owners of Foreign Banks and Agents for Service of 

Legal Process

• Reporting Obligations on Foreign Bank Relationships with Iranian-Linked Financial 

Institutions 

Supersedes:

• SR 21-18, “Release of New and Updated Sections of the Federal Financial Institutions 

Examination Council’s Bank Secrecy Act/Anti-Money Laundering Examination Manual”

Cross-References:

• SR 22-5, “Joint Statement on the Risk-Based Approach to Assessing Customer 

Relationships and Conducting Customer Due Diligence” 

3 See https://bsaaml.ffiec.gov/. 

4 See http://www.federalreserve.gov/apps/contactus/feedback.aspx.