OCC Revises Approach to BSA Compliance

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
David Dickinson

David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

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