Compliance: Start from a place of ‘yes’

Agencies issue statement, RFI on BSA/AML Compliance

April 11, 2021

The federal banking agencies, in consultation with the Financial Crimes Enforcement Network (FinCEN) and NCUA, issued a joint statement Friday addressing how risk management principles described in the “Supervisory Guidance on Model Risk Management” relate to systems or models used by banks to assist in complying with the requirements of Bank Secrecy Act (BSA) laws and regulations.

The statement further notes that it does not alter existing BSA/anti-money laundering (AML) legal or regulatory requirements or establish new supervisory expectations, and that no specific model risk management framework is required.

The agencies, along with NCUA and FinCEN, also announced a request for information (RFI) on the extent to which the principles discussed in the guidance support compliance by banks and credit unions with BSA/AML and Office of Foreign Assets Control requirements.

The agencies are seeking comments and information to better understand bank practices and determine whether additional explanation or clarification may be helpful.

Comments to the RFI will be accepted for 60 days following publication in the Federal Register.