The OCC today issued a bulletin updating the procedure by which banks may respond to potential noncompliance with BSA compliance program requirements or repeat or uncorrected BSA compliance problems.
Under the U.S. Code, the OCC is required to issue a cease-and-desist order when citing BSA compliance violations. When potential noncompliance or an uncorrected issue is identified, the OCC provides bank management with written notice about the violation. The bank then has 15 days to respond to the written notice before the decision to issue a cease-and-desist order is finalized. The OCC reviews the information submitted by the bank before making a determination about whether or not to pursue an enforcement action. For more information, contact ABA’s Rob Rowe.