What examiners are testing in 2026

The October 2025 interagency SAR FAQs exposed a compliance proxy problem that affects most BSA/AML programs. The FFIEC Manual has always required effective, risk-based, and reasonably designed programs. The standard is not new. What the FAQs confirmed is that calendar-based reviews, volume-based filing, and defensive filing do not satisfy it.

What Examiners Are Testing in 2026 translates current examination expectations into what they mean for your program right now, across SAR quality, monitoring governance, independent testing, and board reporting. Practitioner Notes throughout surface the field-level observations that distinguish a defensible program from one that passed prior exams on proxies that are no longer available.