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OCC BULLETIN 2007-36
To: Chief Executive Officers, BSA Officers, and Compliance Officers of All National Banks; Federal Branches and Agencies; Technology Service Providers; Department and Division Heads; and All Examining Personnel

Description: BSA Enforcement Policy

The guidance attached to this bulletin continues to apply to federal savings associations.

The federal banking agencies 1 recently issued an interagency statement (see attached) which provides general policy guidance regarding circumstances in which an agency is required to issue a cease-and-desist order to address noncompliance with Bank Secrecy Act (BSA) requirements. The statement also details standards that agencies will apply when citing a violation of the Suspicious Activity Reporting regulations.

The statement complements the FFIEC BSA/AML Examination Manual and is designed to promote consistency among the agencies with regard to BSA-related enforcement decisions. The statement is also intended to make standards used by regulators in such cases more transparent.

This issuance rescinds OCC Bulletin 2004-50, "Enforcement Guidance for BSA/AML Program Deficiencies."

Ann F. Jaedicke
Deputy Comptroller for Compliance Policy

Daniel P. Stipano
Deputy Chief Counsel

1 Federal banking agencies include the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Office of Thrift Supervision, and the National Credit Union Administration.

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