The FFIEC recently updated its BSA/AML Examination Manual to remove references to “reputational risk.” While the wording has changed, the underlying BSA/AML requirements remain the same. This change stems from a broader regulatory effort to ensure that supervisory decisions are based on objective, measurable risks rather than subjective factors such as reputation.

With the change, no new requirements were added, existing BSA/AML regulatory requirements were not removed or changed, and examiner procedures and expectations were not changed.

What do you need to do?

• If your BSA/AML program references “reputational risk” based on prior regulatory guidance, no immediate change is required, but consider aligning terminology with current regulatory language.
• If your policies or risk assessments rely heavily on reputational risk as a standalone category, ensure focus remains on quantifiable risks.

You can access the FFIEC ‘What’s New’ page here.

CCI suggests sharing this update with your institution’s BSA Officer, Risk Management team, and anyone involved in BSA/AML risk assessments or policy governance. Although the underlying compliance expectations remain unchanged, staying aligned with current terminology ensures clarity and consistency across your BSA/AML program. If you have any questions, please contact us at inquiries@completecompli.com.

Victoria Peterson, CCBCO