BSA/AML Innovative Industry Approaches & Other Related Links

The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network (FinCEN), and the National Credit Union Administration issued a statement encouraging banks to take innovative approaches to meet their Bank Secrecy Act/anti-money laundering (BSA/AML) compliance obligations and further strengthen the financial system against illicit financial activity.

The statement recognizes that private sector innovation, including new ways of using existing tools and adopting new technologies, can help identify suspicious activity and combat money laundering and terrorist financing. Banks are encouraged to consider, evaluate, and where appropriate, responsibly implement innovative approaches in this area. The agencies, however, will not penalize banks that maintain effective anti-money laundering programs but choose not to pursue innovative approaches. The statement makes clear the agencies are committed to continued engagement with the private sector to modernize and innovate in their BSA/AML compliance programs.

In addition, the AML Act of 2020 expressly provides that its purpose is to encourage technology and the adoption of new technology by financial institutions to more effectively counter money laundering and terrorist financing. Several provisions of the AML Act of 2020 specifically address technology including, sections 6202 and 6204 (streamling requirements and electronic submission of reports); sections 6207 and 6208 (subcommittee on innovation and technology and innovation officers; section 6209 (testing methods rulemaking) and 6211 (financial crimes tech symposium).

The OCC established an office of innovation that supports the implementation of responsible innovation and new technology in the financial system. While management of institutions regulated by the OCC should continue to follow existing protocols for communication with their supervisory offices, the OCC Office of Innovation serves as an additional resource and central point of contact to facilitate communication related to innovation and new technology within the federal banking system. Other agencies also have, or will, establish similar projects or offices.

The OCC welcomes industry's feedback on how best to support innovative efforts through supervisory processes, regulations, and guidance. Those wishing to share such feedback in writing with the OCC may do so by sending their submission electronically to innovation @occ.treas.gov. The OCC supports innovation in the BSA/AML areas and national banks and Federal savings associations that are considering innovative approaches and solutions are encouraged to reach out to and coordinate with their examiner-in-charge.

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