Removing Barriers Blog

FinCEN Seeking Info on BSA/AML & OFAC Modeling Guidance
Posted April 12, 2021 by CUNA Advocacy

On April 12, FinCEN, the NCUA, Federal Reserve Board, OCC, and FDIC, issued a Request for Information (RFI) on the extent to which the principles of the Interagency Model Risk Management Guidance (MRMG) support compliance with BSA/AML and OFAC requirements. The MRMG lays out three principles for modeling: (1) model development, implementation, and use; (2) model validation, and (3) governance, policies and control. The agencies want to understand the role of this guidance in compliance practices and whether additional guidance might increase transparency, effectiveness or efficiency.

The Federal Reserve Board and OCC issued the MRMG in interagency supervisory guidance in 2011, and the FDIC adopted it in 2017. NCUA has not adopted the guidance, and as a result, the MRMG does not apply to credit unions. Even so, many credit unions use validated risk modeling systems in their BSA/AML and OFAC compliance programs, including SAR monitoring software. These may be based on the MRMG. 

The RFI includes 12 questions for comment. For more information, check out the Call for Comment or contact Elizabeth LaBerge at