Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor

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11/02/2005 Comptroller Discusses Effects of Uniform Examination Procedures

John C. Dugan, Comptroller of the Currency, in a speech delivered today before the American Bankers Association/American Bar Association Money Laundering Enforcement Conference, stated that the OCC is applying the new uniform examination procedures in all bank examinations. He acknowledged that many bankers are concerned with the length and level of detail in the manual, but insisted “this is one instance in which I think ‘more’ is better.”  For some banks, “application of the new procedures will result in more rigorous examinations due to the increased number of mandatory procedures and the requirement to conduct transaction testing at every examination.” The Comptroller noted that the banks that get into trouble in terms of BSA compliance tend to be the ones “doing the bare minimum that needed to be done to comply with the law.”  This approach, he said, “is simply unacceptable as it subjects the institution to substantial legal and reputational risks.” The Comptroller said that the OCC has established review teams and now tracks and analyzes “Matters Requiring Attention” cited by examiners “so that follow-up can be monitored on a systematic and programmatic basis.” The OCC now holds “nationwide conference calls with its field staff to clarify senior management’s expectations and ensure that there is no ‘disconnect’ between the views of Headquarters and the field.”  

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