• Board of Governors of the Federal Reserve System
  • Federal Deposit Insurance Corporation
  • National Credit Union Administration
  • Office of the Comptroller of the Currency

Federal financial institution regulatory agencies today issued a joint fact sheet clarifying that bank & credit union compliance efforts to meet Bank Secrecy Act due diligence requirements for customers that are charities & other nonprofit organizations should be based on the money laundering risks posed by the customer relationship.

The fact sheet highlights the importance of legitimate charities & nonprofit organizations having access to financial services & being able to transmit funds through legitimate & transparent channels, especially in the context of responding to the coronavirus. It also clarifies that charities & nonprofit organizations as a whole do not present a uniform or unacceptably high risk of being used or exploited for money laundering, terrorist financing, or sanctions violations, & that banks & credit unions must develop risk profiles that are appropriate for the risks presented by each customer. Additionally, it provides examples of customer information that may be useful to banks & credit unions in determining those risk profiles.

The fact sheet does not alter existing Bank Secrecy Act/anti-money laundering legal or regulatory requirements or establish new supervisory expectations. It was developed by the FED, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network, the National Credit Union Administration, & the Office of the Comptroller of the Currency.