OCC Revises Approach to BSA Compliance

As a member of the Association of Certified Anti-Money Laundering Specialists (ACAMS), I receive frequent Deb11updates, news releases, etc., published by the association. Recently, a feature article in ACAMS MoneyLaundering.com reported that the Office of the Comptroller of the Currency (OCC) has revamped the terms under which it will issue and enforce Matters Requiring Attention (MRA) and will be focusing on MRA Compliance. Due to this revision, examiners will be more quick to issue formal enforcement actions against banks that fail to take “timely and effective corrective action” required by MRAs in their previous exams.

The OCC is also revising its approach to allow examiners to issue enforcement actions for violations of the “four pillars” of an AML program, (internal controls, designated qualified BSA officer, staff training, and independent testing).

These revisions were due, in part, to congressional criticism of the agency’s oversight of HSBC USA (in December 2012), which paid $1.9 billion in penalties for failure to properly scrutinize billions of dollars in bulk-cash shipments and trillions of dollars in wires from its Mexican affiliate.

This is a good reminder to all banks (not just OCC regulated) to be at the top of your game when it comes to your BSA/AML Compliance Program!

Deb Irving

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