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OCC Bulletin 2018-44 | December 3, 2018

Bank Secrecy Act/Anti-Money Laundering: Joint Statement on Innovative Efforts to Combat Money Laundering and Terrorist Financing


Chief Executive Officers, BSA Officers, and Compliance Officers of 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 National Credit Union Administration, and the Financial Crimes Enforcement Network (collectively, the agencies) issued today a joint interagency statement to encourage banks to consider innovative approaches in meeting their Bank Secrecy Act/anti-money laundering (BSA/AML) compliance obligations, in order to improve the efficiency and effectiveness of their BSA/AML programs while continuing to protect the national financial system.

Note for Community Banks

The principles contained in this statement apply to all national banks, federal savings associations, and federal branches and agencies.


In the statement, the agencies

  • encourage banks to consider, evaluate, and, when appropriate, responsibly implement innovative approaches to meeting their BSA/AML compliance obligations.
  • recognize the potential such approaches offer for combating money laundering, terrorist financing, and other illicit financial activity, and the role of pilot programs in testing and validating the effectiveness of such approaches.
  • emphasize their commitment to continued and early engagement with bank management to explore innovative approaches, including through pilot programs.
  • reaffirm that they will not penalize or criticize banks that maintain effective BSA/AML compliance programs commensurate with their risk profiles but choose not to pursue innovative approaches.

Further Information

Please contact Spencer W. Doak, Director for BSA/AML Compliance Policy, at (202) 649-5470.


Grovetta N. Gardineer
Senior Deputy Comptroller for Compliance and Community Affairs

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