I'm just curious if anyone is going through the process of changing their policy, procedures, etc. to change references from "BSA/AML" to "AML/CFT" due to the AML Act of 2020. The FDIC is changing their terminology, and we generally follow their lead, but it seems like a lot of work for what seems like an insignificant change.

Bank Secrecy Act (BSA) is the common name for a series of laws and regulations enacted in the United States to combat money laundering and the financing of terrorism. The BSA provides a foundation to promote financial transparency and deter and detect those who seek to misuse the U.S. financial system to launder criminal proceeds, finance terrorist acts, or move funds for other illicit purposes. The Anti-Money Laundering Act of 2020 (the AML Act) modified subchapter II of chapter 53 of title 31 United States Code (the legislative framework commonly referred to as the BSA) and requires financial institutions to have reasonably designed risk-based programs to prevent money laundering and the financing of terrorism. By statute, individuals, banks, and other financial institutions are subject to the BSA recordkeeping requirements. For purposes of consistency with the AML Act, the FDIC now uses the term “AML/CFT rather than “BSA/AML”.

We generally making non-critical updates to our P&P's annually, and will make these revisions then. It's simply not substantive enough to warrant any immediate attention.