The NCUA joined with other federal agencies on Wednesday to remind credit unions and banks of the risk-based approach to assessing customer relationships and conducting customer due diligence.
A joint statement reinforces the position that no single customer type automatically presents a high risk of money laundering, terrorist financing or other illicit financial activity risk, and clarifies the long-standing position that credit unions and banks must take a risk-based approach to assessing individual customer (member) risk.
In addition to the NCUA, the statement was signed by the Board of Governors of the Federal Reserve System, the FDIC, the OCC and the U.S. Department of Treasury’s Financial Crimes Enforcement Network.
In a separate letter to credit unions regarding the joint statement, the NCUA said it expects credit unions to assess the risks posed by each customer individually and “advises against refusing service or discontinuing service to an entire class of customers based on perceived risk.”
Further, credit unions that comply with BSA and AML requirements and have an effective customer due diligence program in place “are well-positioned to manage customer relationships and risks appropriately, based on each individual customer relationship,” the letter states.