In late February, the FFIEC released updates to the BSA/AML Examination Manual to remove references to reputational risk. The action is consistent with Executive Order 14331, which required banking regulators to remove the use of reputation risk or equivalent concepts that could result in politicized or unlawful debanking.

The FFIEC clarified that the updates do not establish new requirements.

The updated BSA/AML Exam Manual can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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