Notification: Statement of Enforcement Policy in Support of Venezuela’s Economic Recovery and Earthquake Relief Efforts

Summary

On July 31, 2026, staffs of the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the National Credit Union Administration (collectively, the agencies), issued a statement of enforcement policy in support of U.S. government efforts to facilitate humanitarian relief and promote financial stability following the recent earthquakes in Venezuela (the Joint Statement). The Joint Statement provides, subject to certain conditions and limitations, that eligible U.S. financial institutions that choose to provide financial services to persons or entities in Venezuela will not be subject to any supervisory action, including citing a violation of law, or subject to an enforcement action by the agencies related to a Bank Secrecy Act (BSA) requirement as a result of providing such authorized financial services. The Joint Statement is intended to reinforce a substantively similar statement by the Department of Treasury's Financial Crimes Enforcement Network (FinCEN), which was issued in consultation with the agencies, regarding its own enforcement policy with respect to providing financial services to persons or entities in Venezuela.¹

Highlights

On June 24, 2026, Venezuela experienced a pair of strong earthquakes off the northern coast, west of Caracas, which have caused significant damage in several cities and triggered a humanitarian crisis in the region. The agencies recognized in the Joint Statement that the timely provision of humanitarian aid can be impaired if institutions that are otherwise able to facilitate the provision of financial services to address the humanitarian crisis are unwilling to do so due to regulatory uncertainty. Accordingly, the agencies committed in the Joint Statement that their supervised entities will not be subject to any supervisory action, including citing a violation of law, or enforcement action related to a BSA requirement as a result of providing authorized financial services in Venezuela. The Joint Statement's commitment applies to authorized financial services provided by an agency-supervised financial institution to persons or entities located in Venezuela from July 31, 2026, through January 29, 2027.

All OCC-supervised institutions may rely on this commitment in the Joint Statement provided that the supervised institution

• is currently in compliance with applicable BSA compliance program requirements and continues to engage in reasonable efforts to comply with applicable BSA requirements, taking into account the government's interests in rapidly providing humanitarian relief and rapidly promoting financial stability in the region;
• has not been the subject of a final enforcement action with FinCEN or the OCC within the prior 24 months that involves violations of BSA requirements; and
• remains compliant with any applicable Office of Foreign Assets Control-administered sanctions regulations and authorizations.

The Joint Statement is intended to recognize that financial institutions exercising reasonable care to avoid violations of applicable BSA requirements in support of Venezuela's economic recovery and earthquake relief efforts are not penalized for actions other than for knowing, willful, or intentional violations of any BSA requirements

The Joint Statement only applies to statutes or regulations specifically addressed in the Joint Statement.

Background

The Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) was enacted on May 24, 2018. Section 201 of the EGRRCPA, titled "Capital Simplification for Qualifying Community Banks," directed each federal banking agency to develop a community bank leverage ratio for qualifying community banks, with qualifying criteria based on the bank's risk profile. In 2019, the federal banking agencies issued a final rule establishing the CBLR framework, which became effective January 1, 2020.

Section 201(c) of the EGRRCPA provides that a qualifying community bank that opts into the CBLR framework and maintains a minimum leverage ratio as set by the federal banking agencies will be considered to have met the generally applicable minimum capital requirements and the capital ratio requirements for the "well-capitalized" category under the Prompt Corrective Action framework.

Section 201(b) of the EGRRCPA further requires each federal banking agency to establish procedures for the treatment of a qualifying community bank whose leverage ratio falls below the CBLR requirement.

Further Information

Please contact Scott Burnett, Special Counsel, Chief Counsel's Office, at (202) 649-5490.

Adam J. Cohen
Senior Deputy Comptroller and Chief Counsel

Related Links

• Joint Statement of Enforcement Policy in Support of Venezuela's Economic Recovery and Earthquake Relief Efforts (PDF)
• FinCEN Statement of Enforcement Policy in Support of Venezuela's Economic Recovery and Earthquake Relief Efforts (PDF)