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OCC Bulletin 2022-18 | July 6, 2022

Bank Secrecy Act/Anti-Money Laundering: Joint Statement on the Risk-Based Approach to Assessing Customer Relationships and Conducting Customer Due Diligence


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, and the National Credit Union Administration (collectively, the agencies) today issued a joint statement to remind banks1 of the risk-based approach to assessing customer relationships and conducting customer due diligence (CDD). The agencies recognize that it is important for customers engaged in lawful activities to have access to financial services. This statement does not alter existing Bank Secrecy Act/Anti-Money Laundering (BSA/AML) legal or regulatory requirements, nor does it establish new supervisory expectations.

Note for Community Banks

The joint statement applies to community banks.


The joint statement explains

  • the agencies are reinforcing 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.
  • banks must adopt appropriate risk-based procedures for conducting ongoing CDD that, among other things, enable banks to
    • understand the nature and purpose of customer relationships in the development of 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.2
  • the agencies' perspective on assessing customer relationships as well as CDD requirements and that it applies to all customer types referenced in the Federal Financial Institutions Examination Council BSA/AML Examination Manual.

Further Information

Please contact James Vivenzio, Director of BSA & AML Policy, Bank Supervision Policy, at (202) 649-5561.


Grovetta N. Gardineer
Senior Deputy Comptroller for Bank Supervision Policy

Related Link

1 Under the Bank Secrecy Act and for purposes of the joint statement, the term bank is defined in 31 CFR 1010.100(d) and includes each agent, agency, branch, or office within the United States of banks, savings associations, credit unions, and foreign banks.

2 Refer to 31 CFR 1020.210(a)(2)(v).