Fiscal Year 2020 Bank Supervision Operating Plan Office of the Comptroller of the Currency Committee on Bank Supervision

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Treliant Takeaway:

The OCC continues to emphasize the importance of Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance, directing is supervisory units and managers to focus on four key areas when developing their 2020 examination plans.  Treliant’s Global Financial Crimes Compliance team knows how to design sustainable BSA/AML and Economic Sanctions programs that stand up to regulatory scrutiny.  Our professionals are former Compliance and BSA/AML officers, FIU directors, investigators, and internal auditors.  We understand how to make programs work and the issues where examiners focus.

Article Highlights:

The OCC’s Fiscal Year 2020 Bank Supervision Operating Plan directs its examination management and staff to focus their work plans on a number of key risk areas, including cybersecurity, credit underwriting, technological innovation, and BSA/AML compliance.  BSA/AML compliance examinations also include Economic Sanctions.

Within the directive pertaining to BSA/AML compliance, the OCC tells its examiners to focus on four key risk areas:

  1. Customer due diligence and beneficial ownership;
  2. Whether BSA/AML risk management systems match the complexity of a bank’s business and products;
  3. Evaluating technology and software that performs or enhances BSA/AML oversight; and,
  4. Assessing the adequacy of suspicious activity monitoring and reporting systems and processes.

Among these four priorities, BSA/AML officers and their teams need to be ready to demonstrate compliance with the new Ultimate Beneficiary Ownership rules, speak to the reasons and process supporting new AML and Economic Sanctions software purchases, defend the annual BSA/AML Risk Assessment approach and results, and be ready for a thorough look at processes of identifying, investigating, and reporting suspicious activity.