Combating Money Laundering and Terrorist Financing:
BSA Enforcement Policies and Actions

           OCC Enforcement Action Policy - The OCC uses informal and formal enforcement actions to ensure national banks' compliance with the BSA. Informal actions are used when identified problems are of limited scope and magnitude and bank management is regarded as committed and capable of correcting them. Formal actions, in the form of a Cease and Desist Order are required whenever a bank fails to establish and maintain a BSA compliance program, as required by 12 CFR 21.21, or fails to correct any problem with its BSA compliance program which was previously cited in a report of examination or other supervisory correspondence. OCC's enforcement policies are detailed in OCC 2007-36.

           Notices of Formal Enforcement - The OCC is required by 12 USC 1818(u) to publicly disclose certain types of agency actions. Once a month, the OCC's Communications Division publishes a list of formal enforcement actions that includes the name of the person or bank involved, the type of action, and the date of the action. The enforcement actions are posted and available at http://www.occ.treas.gov/enforce/enf_search.htm.

            Information Sharing with FinCEN - Under a memorandum of understanding between the U.S. banking agencies and the U.S. Department of Treasury's Financial Crimes Enforcement Network (FinCEN), the OCC will share with FinCEN it's BSA policies, procedures and exam violations or deficiencies