The Clearing House Association submitted a comment letter to the Basel Committee on its consultative document, Sound Management of Risks Related to Money Laundering and Financing of Terrorism. The letter strongly supports international standards on money laundering and terrorist financing because money laundering and terrorist financing are global problems that must be addressed on a global basis. With respect to customer due diligence policies and procedures, the letter argues that any CDD rule should explicitly recognize that a rigid, unvarying approach will not work in all situations and that sound rules and policies should expressly permit institutions to categorize accounts and customers based on their assessment of risks posed by the particular customer and product involved. TCH also supports a risk-based approach to AML risk management.