On December 3, 2018, FinCEN, the Federal Reserve, FDIC, OCC, and NCUA jointly encouraged banks to consider, evaluate, and where appropriate responsibly implement innovative approaches, explicitly including artificial intelligence and digital identity technologies, to meet BSA/AML obligations. The statement says pilot programs that expose gaps in existing programs will not necessarily result in supervisory action, and that the agencies will not penalize banks for maintaining or updating existing processes while testing new ones. It remains the baseline US policy on AI in AML compliance.
OFFICIAL TEXT: fincen.gov ↗ · IN FORCE · FINCEN
| Document | 2018 Joint Statement on BSA/AML Innovation — Joint Statement on Innovative Efforts to Combat Money Laundering and Terrorist Financing |
| Issued by | Financial Crimes Enforcement Network |
| Type | Guidance |
| Status | In force |
| Published | Dec 3, 2018 |
| Effective | Dec 3, 2018 |
| Applies to | Banks, savings associations, and credit unions supervised by the Federal Reserve, FDIC, OCC, and NCUA, and all BSA-covered institutions under FinCEN |
| Official source | fincen.gov ↗ |
| Use cases | AML / KYC · Model risk management · AI governance (general) |
What are the key points of 2018 Joint Statement on BSA/AML Innovation?
- Issued December 3, 2018 by FinCEN with the Federal Reserve, FDIC, NCUA, and OCC
- Names artificial intelligence and digital identity technologies as innovations some banks are already using to strengthen compliance and transaction monitoring
- Pilot programs undertaken in good faith that reveal gaps in a bank's existing BSA/AML program will not necessarily lead to supervisory action
- Banks may test innovative approaches alongside existing processes and will not be penalized for keeping the existing process while a pilot runs
- Innovation is not a safe harbor: banks remain responsible for maintaining effective, risk-based programs and evaluating new tools against BSA requirements
- FinCEN committed to consider requests for exceptive relief under 31 CFR 1010.970 to facilitate testing of new technologies
- Agencies committed to further engagement through innovation offices; FinCEN followed with the Innovation Hours program in 2019
What did 2018 Joint Statement on BSA/AML Innovation change for banks?
Before 2018 many banks feared that piloting machine-learning transaction monitoring would expose weaknesses in their rules-based programs and invite enforcement. The joint statement removed that specific deterrent, put AI on the record as an acceptable AML tool, and set up the run-with-both-systems model that most bank AML AI deployments still follow.
Can a bank get in trouble if an AI pilot uncovers missed SARs?
The 2018 statement says that a pilot program that identifies gaps will not necessarily result in supervisory action, though the bank is still expected to remediate genuine deficiencies in its existing program.
Is the 2018 joint statement still in effect?
Yes. It has not been withdrawn, and its innovation-friendly stance was codified in the Anti-Money Laundering Act of 2020 and repeated in FinCEN's 2024 and 2026 AML/CFT program proposals.
| Date | Document | Status |
|---|---|---|
| Sep 3, 2026 | FIN-2026-Alert005 (Digital Asset Investment Scam Centers) — FinCEN Alert on Money Laundering Activity Associated with Digital Asset Investment Scam Centers | 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 |
| Apr 9, 2021 | 2021 BSA/AML Model Risk Management Statement — Interagency Statement on Model Risk Management for Bank Systems Supporting Bank Secrecy Act/Anti-Money Laundering Compliance | Withdrawn |
Which banks' AI programmes does 2018 Joint Statement on BSA/AML Innovation reach?
6 of the 120 largest US banks profiled on this site cite 2018 Joint Statement on BSA/AML Innovation among the documents their AI work answers to.
Which AI tools for banks does 2018 Joint Statement on BSA/AML Innovation apply to?
The buyer's guides in the AI tools directory name 2018 Joint Statement on BSA/AML Innovation among the rules that apply when a bank uses software in this category.
- AML compliance — BSA/AML innovation policy: Feedzai · Sardine · Alloy · NICE Actimize · Hawk · Quantexa · ComplyAdvantage · Unit21 · SymphonyAI · Abrigo
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