On April 9, 2021 the OCC, Federal Reserve, and FDIC, in consultation with FinCEN and the NCUA, explained how the 2011 model risk management guidance (SR 11-7 / OCC 2011-12) applies to BSA/AML transaction monitoring, sanctions screening, and customer-risk systems. It stressed a risk-based, flexible approach so banks could update AML models quickly, and it was paired with a request for information published April 12, 2021. The statement was rescinded on April 17, 2026 when the agencies replaced the 2011 guidance with revised model risk management guidance (OCC Bulletin 2026-13 / SR 26-2) and did not issue AML-specific replacement guidance.
| Document | 2021 BSA/AML Model Risk Management Statement — Interagency Statement on Model Risk Management for Bank Systems Supporting Bank Secrecy Act/Anti-Money Laundering Compliance |
| Issued by | Financial Crimes Enforcement Network |
| Type | Guidance |
| Status | Withdrawn |
| Published | Apr 9, 2021 |
| Effective | Apr 9, 2021 |
| Applies to | Banks supervised by the OCC, Federal Reserve, and FDIC; issued in consultation with FinCEN and NCUA |
| Also issued as | 2021 BSA/AML Model Risk Statement, OCC Bulletin 2021-19, FDIC FIL-27-2021 |
| Superseded by | OCC Bulletin 2026-13 |
| Official source | federalreserve.gov ↗ |
| Use cases | AML / KYC · Model risk management · Third-party & vendor AI |
What are the key points of 2021 BSA/AML Model Risk Management Statement?
- Issued April 9, 2021 by the OCC (Bulletin 2021-19), Federal Reserve, and FDIC, in consultation with FinCEN and NCUA
- Clarified that not every BSA/AML system is a 'model'; banks decide which systems are models under the 2011 guidance based on their own definitions
- Endorsed a risk-based approach to validation and said rapid updates to AML models (for example, new typologies or FinCEN advisories) need not wait for full revalidation
- Warned against duplicative testing and noted that third-party AML system limitations do not excuse the bank from managing model risk
- Accompanied by an interagency request for information on whether MRM principles support BSA/AML and OFAC compliance, published in the Federal Register April 12, 2021
- Rescinded April 17, 2026 alongside SR 11-7 / OCC 2011-12; OCC Bulletin 2026-13 lists OCC 2021-19 among rescinded issuances
- FDIC now lists its 2021 financial institution letter as inactive
What did 2021 BSA/AML Model Risk Management Statement change for banks?
For five years this was the only federal statement on validating AML models, and banks used it to justify lighter-touch treatment of rules-based monitoring and fast AML model updates. Its rescission in April 2026 means AML machine-learning models are governed only by the general revised model risk framework, which itself excludes generative and agentic AI, so banks must document their own risk-based rationale for how AML models are categorized and validated.
Is the 2021 BSA/AML model risk statement still in effect?
No. It was rescinded on April 17, 2026 when the OCC, Federal Reserve, and FDIC issued revised interagency model risk management guidance. No AML-specific replacement was issued.
What replaced it for AML transaction-monitoring models?
The revised interagency model risk management guidance (OCC Bulletin 2026-13, Fed SR 26-2) applies to all models including AML systems, with a risk-based approach; generative and agentic AI are outside its scope and fall under broader risk management.
| Date | Document | Status |
|---|---|---|
| Apr 17, 2026 | OCC Bulletin 2026-13 — Model Risk Management: Revised Guidance | In force |
| Jul 24, 2026 | FIN-2026-Alert004 (Federal Student Aid Fraud) — FinCEN Alert on Fraud Schemes Targeting Federal Student Aid | In force |
| Apr 10, 2026 | 2026 AML/CFT Program Proposed Rule — Anti-Money Laundering and Countering the Financing of Terrorism Programs (Notice of Proposed Rulemaking, 2026) | Proposed |
| Nov 13, 2024 | FIN-2024-Alert004 (Deepfake Media) — FinCEN Alert on Fraud Schemes Involving Deepfake Media Targeting Financial Institutions | In force |
| Jul 3, 2024 | 2024 AML/CFT Program Proposed Rule (withdrawn) — Anti-Money Laundering and Countering the Financing of Terrorism Programs (Notice of Proposed Rulemaking, 2024) | Withdrawn |
| Jan 1, 2021 | Anti-Money Laundering Act of 2020 — Anti-Money Laundering Act of 2020 (Division F of the National Defense Authorization Act for Fiscal Year 2021) | In force |
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