Objective: Develop an understanding of the bank’s money laundering, terrorist financing (ML/TF), and other illicit financial activity risk profile. Based on the bank’s risk profile, develop a risk-focused examination scope, and document the Bank Secrecy Act/anti-money laundering (BSA/AML) examination plan.

Examiners assess the adequacy of the bank’s Bank Secrecy Act/anti-money laundering (BSA/AML) compliance program, relative to its risk profile, and the bank’s compliance with BSA regulatory requirements. The scoping and planning process enables examiners to understand the money laundering, terrorist financing (ML/TF), and other illicit financial activity risk profile of the bank. The scoping and planning process also enables examiners to focus their reviews of risk management practices and compliance with BSA requirements on areas of greatest ML/TF and other illicit financial activity risks. Examiners assess whether the bank has developed and implemented adequate processes to identify, measure, monitor, and control those risks and comply with BSA regulatory requirements.

The scoping and planning process should include determining BSA/AML examination staffing needs, including technical expertise, and identifying the BSA/AML examination and testing procedures to be completed. The federal banking agencies generally allocate more resources to higher-risk areas and fewer resources to lower-risk areas.

Each section in this manual includes an introductory overview and accompanying examination and testing procedures, as applicable, for examiners to follow.