On July 6, 2022, the FDIC, the Federal Reserve Board, FinCEN, the NCUA, and the OCC issued a joint statement to remind banks of the risk-based approach to assessing customer relationships and conducting customer due diligence (CDD). The agencies clarify that the statement does not alter existing BSA/AML legal or regulatory requirements, nor does it establish new supervisory expectations.
Through the joint statement, the agencies aim to:
Reinforce a longstanding position that no customer type presents a single level of uniform risk or a particular risk profile related to money laundering (ML), terrorist financing (TF), or other illicit financial activity.
Remind banks that they must apply a risk-based approach to CDD when developing the risk profiles of their customers.
Remind banks that they are neither prohibited nor discouraged from providing banking services to customers of any specific class or type.
Encourage banks to manage customer relationships and mitigate risks based on customer relationships, rather than decline to provide banking services to entire categories of customers.
The FDIC’s press release can be found here.
The joint statement can be found here.