Snapshot:
On February 27, 2026, the FFIEC released updates to multiple sections of the BSA/AML Examination Manual, including Suspicious Activity Reporting, Payable Through Accounts, Electronic Banking, and Nondeposit Investment Products. The revisions also formally remove references to “reputational risk” in alignment with Executive Order 14331.
Why it Matters:
These updates signal a continued regulatory shift toward risk‑based, evidence‑driven supervision, reducing ambiguity around subjective “reputational” considerations. BSA/AML teams should review the revised sections to ensure their programs reflect the updated expectations—especially around SAR processes and electronic banking controls. While no new requirements were added, the clarified language may influence examiner focus in upcoming cycles.