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Financial Institution Letter

Joint Statement on Enforcement of Bank Secrecy Act/Anti-Money Laundering Requirements

August 13, 2020  |  FIL-76-2020


The FDIC, along with the Board of Governors of the Federal Reserve System, the National Credit Union Administration, and the Office of the Comptroller of the Currency, is issuing an updated joint statement on enforcement of Bank Secrecy Act/Anti-Money Laundering (BSA/AML) requirements. The joint statement does not create new expectations or standards, but describes circumstances in which an agency will issue a mandatory cease and desist order under section 8(s) of the Federal Deposit Insurance Act to address noncompliance with BSA/AML requirements.

A copy of the Joint Statement can be found on the FDIC’s website.

Statement of Applicability to Institutions: This Financial Institution Letter (FIL) applies to FDIC-supervised banks and savings associations.


  • This statement does not create new expectations or standards. Rather, it is intended to further clarify the agencies’ enforcement of the BSA and the conditions that require the issuance of a mandatory cease and desist order under section 8(s) of the Federal Deposit Insurance Act.
  • The statement clarifies that isolated or technical violations or deficiencies are generally not considered the kinds of problems that would result in an enforcement action.
  • Examples of BSA/AML compliance failures that would result in the issuance of a cease and desist order are included in the statement.
  • The statement also addresses how the agencies evaluate violations of individual components (known as pillars) of the BSA/AML compliance program.
  • The statement describes how the agencies incorporate the Customer Due Diligence regulations and recordkeeping requirements issued by the U.S. Department of the Treasury as part of the internal controls pillar of the bank’s BSA/AML compliance program.
  • The Financial Crimes Enforcement Network issued a “Statement on Enforcement of the Bank Secrecy Act” that sets forth its approach to enforcement in circumstances of non-compliance with the BSA.


FDIC-Supervised Institutions

Suggested Routing:

Chief Executive Officer
BSA Compliance Officer

Related Topics

Bank Secrecy Act
Anti-Money Laundering
Countering the Financing of Terrorism