OCC Supports FinCEN’s Approach to BSA Compliance During Pandemic

The OCC today issued a statement of support for the Financial Crimes Enforcement Network’s approach to Bank Secrecy Act compliance during the coronavirus pandemic. FinCEN on Friday announced relief from certain BSA/AML requirements, including a postponement of new currency transaction reporting requirements.

Importantly, FinCEN also clarified that banks will not be required to re-verify beneficial ownership information when making Paycheck Protection Program loans to existing customers, unless the institution’s own compliance framework required it to do so.

The OCC noted that “when evaluating a bank’s BSA compliance program, the OCC will consider the actions taken by banks to protect and assist employees, customers and others in response to the COVID-19 pandemic, including any reasonable delays in BSA report filings, beneficial ownership verification or re-verification requirements, and other risk management processes.”