Federal Financial Institutions Examination Council removes reputation risk from BSA/AML manual
On February 27, the Federal Financial Institutions Examination Council (FFIEC) released updates to its BSA/AML Examination Manual that removed all references to reputation risk. The FFIEC noted that five sections of the manual were revised: (i) “Introduction”; (ii) “Suspicious Activity Reporting”; (iii) “Payable Through Accounts”; (iv) “Electronic Banking”; and (v) “Nondeposit Investment Products.” The agency explained that the change was made to comply with an August 2025 executive order, which, in relevant part, directed regulatory agencies to eliminate reputation risk considerations from their oversight frameworks (covered by InfoBytes here). The FFIEC stated that while these revisions alter the language in the affected sections, they do not impose any new regulatory requirements on financial institutions.