Customer Due Diligence in the US: FinCEN Says Must Update, the 2018 Exam Manual Still Says Should
The Customer Due Diligence section of the FFIEC BSA/AML Examination Manual, last revised on May 11, 2018 and unchanged as of October 3, 2026, says a bank “should update” customer information that “has materially changed,” while FinCEN’s answer to the…
Philipp ShvedovRead the analysis





