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OCC Bulletin 2011-9 | March 24, 2011

Bank Secrecy Act/Anti-Money Laundering: Guidance on Accepting Accounts From Foreign Embassies, Consulates and Missions


Chief Executive Officers, Bank Secrecy Act Officers, and Compliance Officers of All National Banks, Federal Branches and Agencies, Department and Division Heads, and All Examining Personnel

The guidance attached to this bulletin continues to apply to federal savings associations.

The Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, the Office of Thrift Supervision and the Financial Crimes Enforcement Network are issuing the attached interagency advisory to financial institutions concerning the acceptance of accounts from foreign embassies, consulates and missions. The purpose of the guidance is to clarify that the industry can provide banking services to diplomatic missions and comply with the Bank Secrecy Act. The guidance provides additional examples of ways to structure account relationships to mitigate risk.

The interagency advisory supplements guidance issued in June 2004 addressing account services provided to foreign governments and foreign political figures.

For further information, please contact your examiner-in-charge, OCC supervisory office, or the OCC Compliance Policy Department at (202) 649-5740.

Grovetta N. Gardineer
Deputy Comptroller for Compliance Policy

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