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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."



For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.



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