On July 22, 2019, the Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration, Office of the Comptroller of the Currency (OCC), and the US Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) (collectively, the Agencies) issued a joint statement emphasizing their risk-focused approach to examinations of banks' Bank Secrecy Act/anti-money laundering (BSA/AML) compliance programs. The statement is part of a larger effort to emphasize and enhance the BSA/AML regime (see, for example, Legal Update, US Bank Regulators Release Joint Statement Encouraging Innovative Approaches to Combat Money Laundering and Terrorism Financing). While the statement aims to increase the transparency of the examination process, it does not create new requirements.

The statement outlines common practices for:

Using this approach, the agencies generally are able to allocate more resources to higher-risk areas and fewer resources to lower-risk areas when conducting BSA/AML examinations.

Though examination plans and procedures vary, the statement lays out three commonly used practices for assessing a bank's risk profile, they include:

For more information on banks' BSA/AML obligations, see Practice Note, US Anti-Money Laundering and Trade Sanctions Rules for Financial Institutions.