Articles

CDD & Politically Exposed Persons

December 9, 2020 - 4 min read

The agencies (FinCEN, FDIC, FRB, OCC, and NCUA) (collectively, the Agencies) issued a joint Statement on BSA Due Diligence Requirements for Customers Who May Be Considered Politically Exposed Persons (PEPs) on August 21, 2020 (the PEP Statement). The PEP Statement addresses questions raised by banks on how to apply a risk-based approach to PEPS consistent with…

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Joint Statement on Risk-Focused BSA/AML Supervision

December 18, 2019 - 1 min read

In July 2019, the OCC, FDIC, Federal Reserve, the NCUA, and FinCEN issued a joint statement to emphasize their risk-focused approach to examinations of banks’ Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance programs. This statement is being issued as part of a broader effort to reinforce and enhance the effectiveness and efficiency of the BSA/AML regime….

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Risk Management Guidance for Higher-Loan-to-Value Lending Activities in Communities Targeted for Revitalization

September 30, 2019 - 5 min read

On June 19, 2019, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2019-28 Risk Management Guidance for Higher-Loan-to-Value Lending Activities in Communities Targeted for Revitalization (the 2019 Bulletin) and rescinded its prior bulletin of the same title, OCC Bulletin 2017-28 (issued August 21, 2017) (the 2017 Bulletin). The purpose of the…

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