Financial institutions should apply a risk-based approach and evaluate charities according to their particular characteristics to determine whether they can effectively mitigate the potential risk posed by each. Banks and credit unions must adopt appropriate risk-based procedures for conducting CDD that enable banks to understand the nature and purpose of customer relationships for the purpose of developing a customer risk profile, and conduct ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update customer information. There is no regulatory requirement nor is there a supervisory expectation, for banks and credit union to have unique, additional due diligence steps for charities or other NPOs. The joint fact sheet does not alter existing regulatory requirements and it does not establish new supervisory expectations.
For more information about BSA due diligence requirements, contact Doeren Mayhew’s regulatory compliance advisors.
This publication is distributed for informational purposes only, with the understanding that Doeren Mayhew is not rendering legal, accounting, or other professional opinions on specific facts for matters, and, accordingly, assumes no liability whatsoever in connection with its use. Should the reader have any questions regarding any of the news articles, it is recommended that a Doeren Mayhew representative be contacted.
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