As a member of the Association of Certified Anti-Money Laundering Specialists (ACAMS), I receive frequent 
updates, 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!
Published
2015/02/05
Deb Irving
Deb joined Banker’s Compliance Consulting with twenty years of experience in the banking industry. Her past positions include teller, credit review analyst, assistant financial officer, BSA Officer, Compliance Officer, and Director of Compliance. She has worked for both a small community bank and a large billion-dollar bank.
Deb has Associate Degrees in Business Management and Accounting. She is a graduate of the American Bankers Association National Graduate School of Compliance Management, an honors graduate of Schools of Banking Compliance School, and a graduate of Schools of Banking Advanced School of Banking. Deb’s considerable knowledge and experience make her a valuable member of the Banker’s Compliance Consulting Team. Deb is a Certified Regulatory Compliance Manager (CRCM) and a Certified Anti Money-Laundering Specialist (CAMS).
Deb loves to spend her free time cycling, running, kayaking and weight lifting with her husband. Between them, they have three adult children and six grandchildren. Other interests include anything outdoors and anything she hasn’t done or seen yet!