In our February 5, 2015, blog, we alerted you to the fact that the OCC will be beefing up its BSA/AML examinations. Essentially they will do away with “recommendations” for BSA/AML compliance and will designate BSA/AML problems as either matters requiring attention or violations of law. This means any BSA/AML problems could become enforcement actions if they are not addressed quickly.
James F. Vivenzio, Senior Counsel for Bank Secrecy Act/AML for the OCC, has advised that in light of this policy-shift banks should work closely with their examiners when they encounter a BSA/AML compliance issue in order to show that they are serious about fixing the problem. In turn, the examiners could give the banks more time to address any BSA/AML compliance issues.
While dealing with the formalities of any enforcement action can be tedious, the end result could actually be beneficial for banks. In the past, many times a bank was provided “recommendations” they were expected to follow yet many were based more on examiner opinion than regulatory guidance. With all BSA/AML issues now being included in the Report of Examination (ROE) there is a better chance for clarity and consistency from the upper ranks of the OCC.
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager.
Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelor’s Degree in Business Administration, and is a graduate of the ABA Compliance School.
Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!