On July 6, 2022, the Fed, FDIC, FinCEN, NCUA, and OCC released a joint statement on “The Risk-Based Approach to Assessing Customer Relationships and Conducting Customer Due Diligence” . The statement indicates that it does not modify or establish new expectations of existing laws or regulations, but emphasizes that “no single type of customer presents a single uniform level of risk or a particular risk profile linked money laundering, terrorist financing or other illicit financial activities”. activity.”
The joint statement explains that the Bank Secrecy Act and Anti-Money Laundering (BSA/AML) obligations of banks do not prohibit or discourage institutions from providing banking services to customers of any class or of a specific type and are encouraged to assess and mitigate risks based on customer relationships. instead of refusing to provide banking services to customers of a specific type. Banks are required to adopt customer due diligence procedures that: a risk basis, to maintain and update customer information.
The joint statement also notes that while the FFIEC BSA/AML Examination Handbook provides guidance to banks on the proper execution of BSA/AML examinations, it does not itself establish any requirements, and no risk sections of the FFIEC Handbook associated with money laundering and terrorist financing does not mean that banks should consider certain categories of consumers as presenting a uniformly higher risk.
