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OCC Bulletin 2019-33 | July 22, 2019

Bank Secrecy Act/Anti-Money Laundering: Joint Statement on the Risk-Focused Approach to BSA/AML Supervision


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) today issued a joint statement to clarify and explain their existing risk-focused approach to examinations of financial institutions' Bank Secrecy Act/anti-money laundering (BSA/AML) compliance programs. This statement is intended to increase transparency into the risk-focused approach used by the agencies for planning and performing BSA/AML examinations and does not establish new requirements.

Note for Community Banks

The statement applies to the OCC's supervision of all national banks, federal savings associations, and federal branches and agencies (collectively, banks).


In the joint statement, the agencies

  • recognize the importance of (1) a risk-based compliance program in enabling a bank to allocate compliance resources commensurate with its risk, and (2) a well-developed risk assessment in sound risk management and assisting examiners in understanding a bank's risk profile.
  • explain that examiners tailor examination plans and procedures to a bank's risk profile and describe the common practices examiners use to assess a bank's risk profile.
  • note that examiners review risk assessments and independent testing in determining the examination procedures and transaction testing that should be performed.
  • highlight the foundation established by the risk-focused approach for the information, instructions, and procedures communicated to examiners in the Federal Financial Institutions Examination Council BSA/AML Examination Manual.

Further Information

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


Grovetta N. Gardineer
Senior Deputy Comptroller for Bank Supervision Policy

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