On July 6, 2022, the FED, FDIC, FinCEN, NCUA, and OCC (collectively, the Agencies) released a joint statement clarifying their stance on the risk-based approach currently employed by financial institutions to satisfy customer due diligence requirements. The Agencies state that not all customers of a particular type present a uniform risk level. Instead, additional risk factors should be evaluated to generate a holistic risk-profile. The Agencies once again noted that financial institutions should consider risk at a customer level instead of declining to provide banking services to entire categories of customers (e.g. PATM, NRA, NGO, and MSB).
To read the full statement, please follow this link: