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  • Elizabeth A. McMorrow

U.S. Financial Agencies Issue Joint Statement on Customer Risk

On July 6, 2022, five U.S. agencies responsible for various aspects of the U.S. financial industry issued a "Joint Statement on the Risk-Based Approach to Assessing Customer Relationships and Conducting Customer Due Diligence".

The five agencies are:

  • Board of Governors of the Federal Reserve System

  • Federal Deposit Insurance Corporation

  • Financial Crimes Enforcement Network

  • National Credit Union Administration

  • Office of the Comptroller of the Currency

The agencies reinforced "a longstanding position that no customer type presents a single level of uniform risk or a particular risk profile related to money laundering, terrorist financing, or other illicit financial activity."

The agencies "encourage[d] banks to manage customer relationships and mitigate risks based on customer relationships, rather than decline to provide banking services to entire categories of customers."

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