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4/27/23, 9:07 AM

FACT SHEET: Treasury Department Announces 2023 De-Risking Strategy | U.S. Department of the Treasury

U.S. DEPARTMENT OF THE TREASURY
FACT SHEET: Treasury Department Announces 2023 De-Risking
Strategy
April 25, 2023

WASHINGTON — On April 10, 2023, the U.S. Department of the Treasury published the 2023 Derisking Strategy

pursuant to the Anti-Money Laundering Act of 2020 (AMLA). This fact sheet

summarizes key findings and policy recommendations to address the issue of de-risking,
which refers to financial institutions terminating or restricting business relationships
indiscriminately with broad categories of customers rather than analyzing and managing the
specific risks associated with those customers.
The report’s key findings are:
Profitability is the primary factor in financial institutions’ de-risking decisions, but the
profitability is influenced by a range of factors, such as a financial institution’s available
resources and the cost of implementing Anti-Money Laundering/Countering the Financing
of Terrorism (AML/CFT) compliance measures and systems commensurate with the risk
posed by a customer, among other factors.
The customers facing de-risking challenges most acutely include:
Small and medium-size Money Service Businesses (MSBs) that offer money transmitting
services.
Non-Profit Organizations (NPOs) operating abroad in high-risk jurisdictions.
Foreign financial institutions with low correspondent banking transaction volumes,
particularly those operating in financial environments characterized by high AML/CFT
risks.
This report recommends that the federal government:
Promote consistent supervisory expectations, including through training to federal
examiners, that consider the effects of de-risking;
Analyze account termination notices and notice periods that banks give NPO and MSB
customers and identify ways to support longer notice periods where possible;
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FACT SHEET: Treasury Department Announces 2023 De-Risking Strategy | U.S. Department of the Treasury

Consider proposing regulations that require financial institutions to have reasonably
designed and risk-based AML/CFT programs supervised on a risk basis, possibly taking into
consideration the effects of financial inclusion;
Consider clarifying and revising AML/CFT Bank Secrecy Act (BSA) regulations and guidance
for MSBs;
Bolster international engagement to strengthen the AML/CFT regimes of foreign
jurisdictions;
Expand international cooperation and consider creative options, such as regional
consolidation projects, with our international counterparts;
Support efforts by international financial institutions to address de-risking through related
projects and technical assistance;
Continue to assess the opportunities, risks, and challenges of innovative and emerging
technologies for AML/CFT compliance solutions;
Build on Treasury’s work to modernize the U.S. sanctions regime and its recognition of the
need to specifically calibrate sanctions to mitigate unintended economic, political, and
humanitarian impacts;
Reduce burdensome requirements for processing humanitarian assistance transactions;
Track and measure aggregate changes in banking relationships with respondent banks,
MSBs, and NPOs; and
Encourage ongoing public and private sector engagement with MSBs, NPOs, banks and
regulators.
As noted in the strategy, these policy options offer the potential for positive impact that
outweigh the assessed risk and leverage Treasury’s relevant policy tools and authorities. While
no individual recommendation is likely to be transformative on its own, Treasury believes the
recommendations will have positive cumulative effects on the issue of de-risking.
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