In the November 2025 issue of our magazine, Banking on BCC, we discussed that the OCC has been one of the more active agencies in taking steps to reduce the supervisory burden on community banks. Since then, they’ve issued additional …supervisory and regulatory actions to reduce burden for community banks and strengthen their service as drivers of economic growth.
Bulletin 2025-37 establishes minimum BSA/AML examination procedures for community banks and provides guidance to examiners on how to implement them. These will go into effect for examinations beginning February 1, 2026. While these examination procedures do still align closely to the FFIEC’s BSA/AML Examination Manual, they do give examiners some additional discretion to reduce the scope and burden of such exams. For example, examiners may exercise discretion to rely on independent testing deemed adequate by examiners for each section and to determine whether to carry forward prior examination conclusions for the Training and BSA Officer pillars, where appropriate. They may also …determine whether or to what degree transaction testing should be performed or whether testing should be limited to analytical or other reviews.
We’ve got a lot of great BSA/AML/CFT training coming up in 2026 so be sure to check it out!
Published
2025/12/26
