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OCC Bulletin 2020-77
August 21, 2020
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Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties
The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Financial Crimes Enforcement Network today issued a joint statement to address certain questions raised by financial institutions related to Bank Secrecy Act (BSA) and anti-money laundering (AML) regulatory requirements for customers whom banks may consider to be politically exposed persons.
This bulletin and joint statement rescind OCC Bulletin 2001-9, "Bank Secrecy Act/Anti-Money Laundering: Guidance on Foreign Official Corruption," and its attachment, "Guidance on Enhanced Scrutiny for Transactions That May Involve the Proceeds of Foreign Official Corruption."
This bulletin applies to community banks.1
Please contact James Vivenzio, Acting Director for BSA/AML Policy, at (202) 649-5470.
Grovetta N. Gardineer
Senior Deputy Comptroller of Bank Supervision Policy
1 "Banks" refers collectively to national banks, federal savings associations, and federal branches and agencies of foreign banking organizations.
2 "Senior foreign political figure" connotes a subset under the concept of politically exposed persons that is specific to the context of private banking. Refer to 31 CFR 1010.605(p) and 1010.620.
3 "Customer Due Diligence Requirements for Financial Institutions," 81 Fed. Reg. 29398 (May 11, 2016). Refer to 31 CFR 1010, 1020, 1023, 1024, and 1026.