BSA Exam Manual Update: Identifying & Mitigating BSA Risks

Do you know about the BSA update trifecta? There were three updates to the BSA exam manual in 2021. Do those additions to the already hefty set of BSA regulations leave you wanting for answers? This is the update you need to ensure your program is compliant and will pass the next exam.


  • Understand the factors to effectively identify high-risk customers
  • Use the updates to predict expected risk-mitigation steps
  • Anticipate examiner expectations in three new subsections for “Examiner Evaluation”
  • Determine if your BSA/AML program meets the standards for customer risk profiles
  • Evaluate procedures for monitoring independent ATM owners

The BSA exam manual was updated three times in 2021, most recently on December 1, 2021. While the FFIEC press release said the updates are not “new” requirements, they provide critical insight into the priorities for BSA exams. Is your BSA/AML program adequate and will it pass the next exam?

The December 1st update added a new introductory section. Additional changes were made to:

  • Charities and Nonprofit Organizations
  • Independent Automated Teller Machine Owners or Operators
  • Politically Exposed Persons (PEPs)

This informative session is designed for staff who manage the BSA/AML program and train employees. It will benefit BSA officers and staff, senior management, security/risk managers, compliance officers, auditors, and legal counsel.


  • Template for CDD policy and procedures
  • SAR checklist to identify, monitor, and report suspicious activity based on BSA exam procedures and the risk assessment process
  • Sample BSA responsibility matrix, including SAR monitoring and CIP
  • Format for quarterly BSA/AML/OFAC report to the board
  • PDF of slides and speaker’s contact info for follow-up questions
  • Attendance certificate provided to self-report CE credits
  • Employee training log
  • Interactive quiz

NOTE: All materials are subject to copyright. Transmission, retransmission, or republishing of any webinar to other institutions or those not employed by your agency is prohibited. Print materials may be copied for eligible participants only.

MEET THE PRESENTER – Susan Costonis, Compliance Training and Consulting for Financial Institutions
Susan Costonis is a compliance consultant and trainer who began her career in 1978. She specializes in compliance management along with deposit and lending regulatory training. Costonis has successfully managed compliance programs and exams for institutions that ranged from a community bank to large multi-state bank holding companies. She has been a compliance officer for institutions supervised by the OCC, FDIC, and Federal Reserve. Costonis has been a Certified Regulatory Compliance Manager since 1998, completed the ABA Graduate Compliance School, and graduated from the University of Akron and the Graduate Banking School of the University of Colorado. She regularly presents to financial institution audiences in several states and “translates” complex regulations into simple concepts by using humor and real-life examples.


  • $245 – Live Webinar Access
  • $245 – OnDemand Access + Digital Download
  • $320 – Both Live & On-Demand Access + Digital Download


Mar 02 2022


10:00 am - 11:30 am



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