# 2021 BSA/AML Model Risk Management Statement: Interagency Statement on Model Risk Management for Bank Systems Supporting Bank Secrecy Act/Anti-Money Laundering Compliance

Source: https://www.bankingnewsai.com/ai-regulation/documents/fincen-bsa-aml-model-risk-statement-2021
Last updated: Aug 26, 2026

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 The statement was rescinded on April 17, 2026 when the agencies replaced the 2011 guidance with revised model risk management guidance (OCC Bulletin 2026-13 / SR 26-2) and did not issue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.

## At a glance

| Field | Value |
| --- | --- |
| Authority | [FinCEN](https://www.bankingnewsai.com/ai-regulation/fincen) |
| 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| Status | Withdrawn |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 |
| Official text | https://www.federalreserve.gov/newsevents/pressreleases/bcreg20210409a.htm |

## Key points

- 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- Rescinded April 17, 2026 alongside SR 11-7 / OCC 2011-12; OCC Bulletin 2026-13 lists OCC 2021-19 among rescinded issuances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 changed 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.

## Use cases it governs

- [AML / KYC](https://www.bankingnewsai.com/ai-regulation/by-use-case#aml-kyc)
- [Model risk management](https://www.bankingnewsai.com/ai-regulation/by-use-case#model-risk)
- [Third-party & vendor AI](https://www.bankingnewsai.com/ai-regulation/by-use-case#third-party-vendors)

> Superseded by [OCC Bulletin 2026-13](https://www.bankingnewsai.com/ai-regulation/documents/occ-bulletin-2026-13).

Same interagency text issued as: [2021 BSA/AML Model Risk Statement](https://www.bankingnewsai.com/ai-regulation/documents/fed-bsa-aml-model-risk-statement-2021), [OCC Bulletin 2021-19](https://www.bankingnewsai.com/ai-regulation/documents/occ-bulletin-2021-19), [FDIC FIL-27-2021](https://www.bankingnewsai.com/ai-regulation/documents/fdic-fil-27-2021).

## FAQ

### 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.

## Related documents

- [OCC Bulletin 2026-13](https://www.bankingnewsai.com/ai-regulation/documents/occ-bulletin-2026-13) — Model Risk Management: Revised Guidance (Apr 17, 2026)
- [FIN-2026-Alert005 (Digital Asset Investment Scam Centers)](https://www.bankingnewsai.com/ai-regulation/documents/fincen-alert-2026-scam-centers) — FinCEN Alert on Money Laundering Activity Associated with Digital Asset Investment Scam Centers (Sep 3, 2026)
- [FIN-2026-Alert004 (Federal Student Aid Fraud)](https://www.bankingnewsai.com/ai-regulation/documents/fincen-alert-2026-federal-student-aid-fraud) — FinCEN Alert on Fraud Schemes Targeting Federal Student Aid (Jul 24, 2026)
- [2026 AML/CFT Program Proposed Rule](https://www.bankingnewsai.com/ai-regulation/documents/fincen-aml-cft-program-nprm-2026) — Anti-Money Laundering and Countering the Financing of Terrorism Programs (Notice of Proposed Rulemaking, 2026) (Apr 10, 2026)
- [FIN-2024-Alert004 (Deepfake Media)](https://www.bankingnewsai.com/ai-regulation/documents/fincen-alert-2024-deepfake-media) — FinCEN Alert on Fraud Schemes Involving Deepfake Media Targeting Financial Institutions (Nov 13, 2024)
- [2024 AML/CFT Program Proposed Rule (withdrawn)](https://www.bankingnewsai.com/ai-regulation/documents/fincen-aml-cft-program-nprm-2024) — Anti-Money Laundering and Countering the Financing of Terrorism Programs (Notice of Proposed Rulemaking, 2024) (Jul 3, 2024)
- [Anti-Money Laundering Act of 2020](https://www.bankingnewsai.com/ai-regulation/documents/fincen-aml-act-2020) — Anti-Money Laundering Act of 2020 (Division F of the National Defense Authorization Act for Fiscal Year 2021) (Jan 1, 2021)
- [FinCEN Innovation Hours](https://www.bankingnewsai.com/ai-regulation/documents/fincen-innovation-hours-2019) — FinCEN's Innovation Initiative: Implementation of FinCEN Innovation Hours; Invitation to Request Innovation Hours Meeting (May 1, 2019)

Last reviewed Aug 26, 2026. Cite the official text (https://www.federalreserve.gov/newsevents/pressreleases/bcreg20210409a.htm) for the rule and this page for the summary and dates.

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