The Agencies issued a joint Fact Sheet that lists considerations for a risk-based approach when it comes to charities and nonprofits. While the Fact Sheet purports to not impose additional obligations on banks, it is hard to view the “considerations” as anything but.
On November 19, 2020, the Federal Reserve, the FDIC, the FinCEN, the NCUA, and the OCC (collectively, Agencies) issued a press release and joint fact sheet (Fact Sheet) to provide clarity to banks on how to apply a risk-based approach to charities and other nonprofit organizations (NPOs), consistent with the customer due diligence (CDD) requirements contained in FinCEN’s CDD Rule.