On July 31, staffs of the Fed, the FDIC, the OCC, and NCUA jointly issued a statement of enforcement policy declining to pursue BSA enforcement against supervised financial institutions that provide authorized financial services to persons or entities in Venezuela in support of the country’s economic recovery and earthquake relief efforts. The agencies stated the commitment was intended to support U.S. government efforts to facilitate humanitarian relief and promote financial stability following a pair of earthquakes that struck off Venezuela’s northern coast on June 24, reinforcing a substantively similar policy statement issued by FinCEN on July 27.

Under the statement, the agencies committed that supervised institutions will not be subject to any supervisory action, including a citation for a violation of law, or an enforcement action related to a BSA requirement, the USA PATRIOT Act, or other anti-money laundering laws as a result of providing authorized financial services in Venezuela, with the commitment applying to services provided from July 31, 2026, through January 29, 2027. The agencies asserted that a supervised institution may rely on the commitment if it: (i) is currently in compliance with applicable BSA compliance program requirements; (ii) continues to engage in reasonable efforts to comply with BSA requirements; (iii) has not been the subject of a final BSA-related enforcement action with FinCEN or the applicable agency within the prior 24 months; and (iv) remains compliant with applicable sanctions regulations and authorizations administered by the Office of Foreign Assets Control.