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OCC Bulletin 2020-101 | November 19, 2020

Bank Secrecy Act/Anti-Money Laundering: Joint Fact Sheet on Charities and Nonprofit Organizations


Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties


The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network (FinCEN), and the National Credit Union Administration (collectively, the agencies) today issued a joint fact sheet recognizing the important role of charities and other nonprofit organizations during the coronavirus pandemic. The joint fact sheet clarifies how banks1 may provide services to charities and other nonprofit organizations consistent with FinCEN's risk-based approach for conducting customer due diligence.

Note for Community Banks

The joint fact sheet applies to the OCC's supervision of community banks.


The joint fact sheet

  • explains that the level and type of customer due diligence should be appropriate for the risks presented by each customer, including charities and other nonprofit organizations.
  • notes that FinCEN's 2016 Customer Due Diligence rule does not create a regulatory requirement, and there is no supervisory expectation, for banks to have unique, additional due diligence steps for charities or other nonprofit organization customers.
  • provides considerations that may be useful to banks when determining the customer risk profile of a charity or other nonprofit organization.

Further Information

Please contact Jim Vivenzio, Acting Director for BSA/AML Policy, at (202) 649-5470.


Grovetta N. Gardineer
Senior Deputy Comptroller for Bank Supervision Policy

Related Link

1 "Banks" refers collectively to national banks, federal savings associations, and federal branches and agencies of foreign banking organizations.