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OCC BULLETIN 2014-58
To: Chief Executive Officers of All National Banks, Federal Savings Associations, Federal Branches and Agencies of Foreign Banks, Department and Division Heads, All Examining Personnel, and Other Interested Parties

Description: Statement on Risk Management

Summary

The Office of the Comptroller of the Currency (OCC) is issuing the “Statement on Risk Management Associated With Money Services Businesses” to provide clarification to national banks, federal savings associations, and federal branches and agencies of foreign banks (collectively, banks) on the agency’s supervisory expectations with regard to offering banking services to money services businesses (MSB).

Note for Community Banks

The principles contained in the statement below are applicable to all OCC-supervised banks.

Highlights

As detailed in the statement below,

  • the OCC does not direct banks to open, close, or maintain individual accounts, nor does the agency encourage banks to engage in the termination of entire categories of customers without regard to the risks presented by an individual customer or the bank’s ability to manage the risk.
  • MSBs present varying degrees of risk.
  • banks are expected to assess the risks posed by an individual MSB customer on a case-by-case basis and to implement controls to manage the relationship commensurate with the risks associated with each customer.

Statement on the Risk Management Associated With Money Services Businesses

In carrying out the agency’s mission, the OCC requires OCC-supervised banks to manage their risks appropriately, to meet the needs of their communities, to comply with laws and regulations, and to provide fair access to financial services and fair treatment of their customers. As a general matter, the OCC does not direct banks to open, close, or maintain individual accounts, nor does the agency encourage banks to engage in the termination of entire categories of customer accounts without regard to the risks presented by an individual customer or the bank’s ability to manage the risk.

The OCC has always taken the position that banks must apply the requirements of the Bank Secrecy Act based on their own assessment of risk for all customer accounts. A bank’s risk assessment should take into account the products and services it offers the customer as well as the customer’s individual circumstances. The safety and soundness of an institution can be threatened when a bank lacks appropriate risk management systems and controls for the products or activities it provides or the customers it serves. Moreover, the failure to implement and maintain such controls can provide money launderers, fraudsters, terrorists, and other criminals with access to our financial system.

MSBs present varying degrees of risk to an institution. Not all MSBs should be considered high risk. In keeping with the OCC’s mission and commitment to ensuring all customers have fair access to financial services, the agency expects OCC-regulated banks to assess the risks posed by each MSB customer on a case-by-case basis and to implement appropriate controls to manage the relationship commensurate with the risks associated with each customer.

Further Information

Please contact Grovetta N. Gardineer, Deputy Comptroller for Compliance Operations and Policy, at (202) 649-5470.

Grovetta N. Gardineer
Deputy Comptroller for Compliance Operations and Policy