In an unusual move, Laura Akahoshi, former Rabobank (the “Bank”) Chief Compliance Officer (“CCO”), filed on July 6, 2023 an opposition to the Office of the Comptroller of the Currency’s (“OCC”) dismissal of its own...more
Examiners Should Focus on Risk, Not Technical Perfection - On April 15, 2020, the Federal Financial Institutions Examination Council (“FFIEC”) released updates to the Bank Secretary Act/Anti-Money Laundering (“BSA/AML”)...more
Financial Institutions ought to design and evaluate compliance programs to meet BSA/AML requirements and to satisfy Bank Examiner expectations. A Financial Institution’s Compliance Programs must comply with the requirements...more
Last month the Financial Crimes Enforcement Network (FinCEN) and the federal bank regulators issued a Joint Statement aimed at improving transparency into their risk-focused examination and supervision of banks’ compliance...more
Incorporation Solidifies Customer Due Diligence as “Fifth Pillar” to BSA/AML Compliance Program - May 11, 2018 was the much anticipated effective date for the Customer Due Diligence (“CDD”) Requirements for Financial...more
The Federal Financial Institutions Examination Council (FFIEC) has released its revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. The revisions clarify supervisory expectations and incorporate...more
On June 18, 2013, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspective highlighting current risks for national banks and federal savings associations. The report, available here, offers...more