OCC Notes Importance of BSA/AML Elements in Novel Digital Asset Activities
Highlights
A recent Office of the Comptroller of the Currency consent order highlights the necessity of various controls, procedures, monitoring, training and staffing in supporting for fintech, digital asset, and financial service providers
Bank Secrecy Act/anti-money laundering programs must be supported by sufficient customer due diligence
Such programs must also include sufficient procedures and controls for monitoring and reporting suspicious activity
Further, these programs must staff and train a sufficient number of personnel and qualified individuals in support
The Office of the Comptroller of the Currency (OCC) recently issued a consent order relating to the adoption and implementation of certain compliance program elements covering the Bank Secrecy Act (BSA), as well as anti-money laundering (AML), combating the financing of terrorism (CFT), and due diligence requirements. The order highlights the important role sufficient controls, procedures, monitoring, training and staffing play in supporting BSA, AML, and other suspicious activity related programs.
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