ABA Banking Journal
No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
SUBSCRIBE
ABA Banking Journal
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
No Result
View All Result
No Result
View All Result
Home Compliance and Risk

OCC Issues Guidance on AML/BSA Risk Management

October 5, 2016
Reading Time: 2 mins read

As promised by Comptroller of the Currency Thomas Curry last week, the OCC today released guidance articulating its expectations for banks with respect to terminating foreign correspondent relationships. The guidance addresses the recent “derisking” trend in anti-money laundering and Bank Secrecy Act compliance.

The guidance directs banks to establish and implement procedures for periodically reevaluating the risk posed by foreign correspondent relationships, taking into account the risks present in foreign institutions’ business and markets, the anticipated account activity and the supervisory regime of the geographic location in which the foreign financial institution is licensed. Reevaluations should be performed periodically for all foreign correspondent accounts, and banks making decisions to terminate foreign correspondent relationships should base their determinations on these reevaluations.

Along with the guidance, the OCC included “best practices” for banks when conducting risk reevaluations, which include establishing a governance function to review and monitor recommendations regarding foreign account termination; ensuring that decisions are properly communicated to both senior management and the foreign financial institution in question (if permitted by law); and ensuring proper documentation of the decision-making process before taking any steps to terminate a foreign correspondent accounts. As part of that process, the agency expects banks to consider the effects account closure might have on the foreign correspondent, particularly with respect to accessing banking services.

Unlike most BSA/AML guidance typically released under a joint-agency approach, the guidance was issued independently by the OCC and without industry input. ABA is currently in the process of analyzing the guidance, but fears that the expectations outlined by the agency (which are often interpreted as mandates by examiners) could ultimately serve to perpetuate the derisking trend rather than curb it. Additionally, ABA noted that establishing a set of requirements that must be met before a bank can terminate a foreign correspondent relationship may run contradictory to the agency’s claim that it “does not direct banks to open, close or maintain individual accounts.” For more information, contact ABA’s Rob Rowe.

Tags: Anti-money launderingBank Secrecy ActDerisking
ShareTweetPin

Author

Monica C. Meinert

Monica C. Meinert

Monica C. Meinert is a senior editor at the ABA Banking Journal and VP for executive communications at the American Bankers Association.

Related Posts

Five tips to juice community bank board performance

New survey probes community banks’ plans for digital assets

Community Banking
October 6, 2026

Double-digit shares of community bankers intend to offer tokenized deposits and stablecoin solutions within the next 12 months, according to the Conference of State Bank Supervisors' 2026 community bank survey released today. 

ABA, MBA release ad encouraging Sen. Hyde-Smith to continue championing economic growth

ABA, MBA release ad encouraging Sen. Hyde-Smith to continue championing economic growth

Newsbytes
October 6, 2026

ABA and the Mississippi Bankers Association have released a new ad applauding Sen. Cindy Hyde-Smith’s (R-Miss.) support for policies that drive economic growth in local communities and urging her to continue those efforts.

ABA seeks more coordination among banking agencies in rewriting disclosure rules

ABA seeks more coordination among banking agencies in rewriting disclosure rules

Compliance and Risk
October 6, 2026

As they restructure the processes for making confidential bank information available for public review, regulators should better coordinate their efforts to ensure banks do not face differing disclosure requirements, ABA said.

FDIC’s Hill: Standards-setting organization could spur bank-fintech partnerships

ABA announces investment in BankTech Ventures

Community Banking
October 6, 2026

The investment reflects ABA's ongoing commitment to identifying innovative technologies and companies that can deliver value to banks and their customers.

Fed’s Bowman to keynote ABA Conference for Community Bankers

Fed to split bank supervision into five regions

Community Banking
October 6, 2026

The Federal Reserve will divide its bank supervision into five geographic regions rather than splitting it among the 12 Reserve Bank districts, Vice Chair for Supervision Michelle Bowman said. The Fed also plans to revisit the criteria used...

ABA highlights banker comments seeking stronger ‘know your customer’ rules for originating providers

Lawmakers propose banning SIM boxes used in scam calls

Compliance and Risk
October 5, 2026

A proposed bill would ban the sale and manufacturing of machines that help scammers disguise their phone calls and texts.

NEWSBYTES

ABA, MBA release ad encouraging Sen. Hyde-Smith to continue championing economic growth

October 6, 2026

ABA seeks more coordination among banking agencies in rewriting disclosure rules

October 6, 2026

ABA announces investment in BankTech Ventures

October 6, 2026

SPONSORED CONTENT

The Shift from Demographic Marketing

The Shift from Demographic Marketing

October 1, 2026
Meeting Ag Lending Goals Without Going It Alone

Meeting Ag Lending Goals Without Going It Alone

October 1, 2026
Beyond the Portfolio: The Wealth Manager’s New Role in a Multigenerational World

Beyond the Portfolio: The Wealth Manager’s New Role in a Multigenerational World

September 17, 2026
Banking Technology at a Strategic Crossroads

Banking Technology at a Strategic Crossroads

September 8, 2026

PODCASTS

Podcast: Creating seamless customer experiences

September 30, 2026

Podcast: Telling a different kind of story about community banks

September 28, 2026

Podcast: Making the jump from a high performer to a high-performing leader

September 16, 2026

American Bankers Association
1333 New Hampshire Ave NW
Washington, DC 20036
1-800-BANKERS (800-226-5377)
www.aba.com
About ABA
Privacy Policy
Contact ABA

ABA Banking Journal
About ABA Banking Journal
Media Kit
Advertising
Subscribe

© 2026 American Bankers Association. All rights reserved.

No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive

© 2026 American Bankers Association. All rights reserved.