On 4/9/2021, the federal banking agencies, along with the Financial Crimes Enforcement Network (FinCEN) and the NCUA, issued a joint statement addressing “how risk management principles described in the ‘Supervisory Guidance on Model Risk Management’ relate to systems or models used by banks to assist in complying with the requirements of Bank Secrecy Act (BSA) laws and regulations.” The statement also explains that it does not alter existing BSA/anti-money laundering (AML) legal or regulatory requirements or establish new supervisory expectations, and that no specific model risk management framework is required.
In addition, the agencies also announced a request for information (RFI) on the extent to which the principles discussed in the guidance support compliance by banks and credit unions with BSA/AML and Office of Foreign Assets Control requirements. In their release, FinCEN explained that they are seeking comments and information to better understand bank practices and determine whether additional explanation or clarification may be helpful.
The FDIC’s version of the joint statement can be found here.
The RFI can be found here.
