News & Analysis as of

Risk Management BSA/AML Office of the Comptroller of the Currency

Orrick, Herrington & Sutcliffe LLP

OCC announces enforcement actions for August 2024

On August 22, the OCC released a list of recent enforcement actions against national banks, federal savings associations, and individuals affiliated with such entities (defined as institution-affiliated parties, or IAPs). The...more

Troutman Pepper

Federal Banking Agencies Issue New Guidebook for Community Banks Managing Third-Party Relationships

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On May 3, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency (collectively, the agencies) released a guidebook aimed at assisting...more

Ballard Spahr LLP

Federal Banking Agencies Issue Guide to Third-Party Risk Management Practices for Community Banks

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On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the...more

Sheppard Mullin Richter & Hampton LLP

South Dakota Lenders on Tight Deadline for BSA/AML Compliance

On January 12, South Dakota’s Division of Banking issued a mandate setting March 31, 2024 as the deadline for all South Dakota licensed money lenders and non-residential mortgage brokers to comply with their Bank Secrecy...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2023

A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more

Ballard Spahr LLP

OCC Risk Perspective Report Focuses on Third-Party Relationships with Fintechs

Ballard Spahr LLP on

In its Fall 2023 Semiannual Risk Perspective, published on December 7, the Office of the Comptroller of the Currency (“OCC”) reported on key issues facing the federal banking system. In evaluating the overall soundness of...more

Troutman Pepper

OCC’s Semiannual Report Highlights Emerging Risk of AI in Banking

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On December 7, the Office of the Comptroller of the Currency (OCC) published the fall edition of its Semiannual Risk Perspective, which discusses key issues facing banks. From the OCC’s perspective, the overall strength of...more

Morrison & Foerster LLP

Banking Agencies Issue Joint Third-Party Risk Management Guidance

On June 9, 2023, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) published final joint guidance on managing...more

Sheppard Mullin Richter & Hampton LLP

OCC Highlights Focus on Crypto and Bank-FinTech Partnerships, Anticipates Stricter Scrutiny Going Forward

On September 7, Acting Comptroller of the Currency, Michael Hsu, discussed the long-term threats to trust in banking in remarks at the TCH + BPI Annual Conference. Hsu provided updates on key priorities at the OCC, including...more

Venable LLP

Bank Provider of BaaS Dinged by OCC; Blueprint for Fintech Partnerships?

Venable LLP on

​​​​​​​A recent action by the Office of the Comptroller of the Currency (OCC) highlights how banks need to ensure that they have robust compliance programs for managing risks posed by their banking as a service (BaaS)...more

Perkins Coie

Fintech Legal Report - July 2021

Perkins Coie on

President Biden Issues an Executive Order on Competition with Implications for Financial Institutions - On July 9, 2021, President Biden issued an Executive Order on Promoting Competition in the American Economy. The...more

Foodman CPAs & Advisors

Agencies Request Information To Assist With BSA Laws And Regulations Compliance

On April 9, 2021, the federal banking regulatory agencies (the Federal Reserve, FDIC and OCC) together with FinCEN and the National Credit Union Administration issued a joint statement addressing how risk management...more

Ballard Spahr LLP

Risk Management: Agencies Issue Request for Information on Intersection of Model Risk Management Guidance and BSA/AML Compliance

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On April 12, 2021, the Office of the Comptroller of the Currency (“OCC”), the Board of Governors of the Federal Reserve System (“Board”), the Federal Deposit Insurance Corporation (“FDIC”), the National Credit Union...more

Morgan Lewis - All Things FinReg

OCC Issues Clarification on Stablecoin Custody Services

On the heels of an interpretive letter allowing national banks and federal savings associations (FSAs) to provide cryptocurrency custody services to customers (see our LawFlash), the US Office of the Comptroller of the...more

Ballard Spahr LLP

OCC Semiannual Risk Perspective Highlights Cybersecurity, Fraud, Money Laundering Concerns

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Last week, the Office of the Comptroller of the Currency (“OCC”) published the Spring 2018 Semiannual Risk Perspective (the “Report”), which uses up-to-date data to identify risks to U.S. banks and measure their compliance...more

Ballard Spahr LLP

OCC Report: Same Threats, Different Season

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OCC Identifies AML/BSA and Cyber Threats as Elevated Risks Facing Banks - Last week, the Office of the Comptroller of the Currency (“OCC”) published the Spring 2018 Semiannual Risk Perspective (the “Report”), which uses...more

Nutter McClennen & Fish LLP

Nutter Bank Report, March 2017

Fed Raises Threshold That Triggers Review of Systemic Risk of a Proposed Merger - In a recent decision on a proposed merger of two bank holding companies, the Federal Reserve indicated that it has increased the...more

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