On July 22, 2019, the federal financial institution regulatory agencies (NCUA, CFPB, OCC, FDIC, Federal Reserve) issued the Joint Statement on Risk-Focused Bank Secrecy Act/Anti-Money Laundering Supervision. The joint statement emphasizes the risk-based approach examiners are taking during BSA/AML examinations. It does not set any new standards or requirements.

Financial institutions are expected to utilize a risk-based BSA/AML compliance program, which is heavily dependent on their risk assessment. Examiners review a financial institution’s BSA/AML compliance program relative to its own unique risk profile. Consequently, every financial institution BSA/AML examination is different. In general, examiners spend less time on those areas deemed lower risk by the financial institution and where there are high-quality risk management processes in place to combat potential money laundering, terrorist financing and other illicit financial activity.


John Zasada, JD, CAMS – Regulatory Consulting Director, Financial Institutions Group. John can be reached at zasada@doeren.com.