OCC 2004-34
OCC Bulletin

Subject:      Bank Secrecy Act
Description:  Examination Procedures

Date:         July 28, 2004
 
TO:  Chief Executive Officers and Compliance Officers of All National Banks, 
     Department and Division Heads, and All Examining Personnel

The USA PATRIOT Act, signed into law on October 26, 2001, establishes new and 
enhanced measures to prevent, detect, and prosecute money laundering and 
terrorism.  The measures directly affecting national banks have been set forth 
as amendments to the Bank Secrecy Act (BSA) (31 CFR 103).  The regulation 
implementing section 326 of the act that addresses customer identification 
program requirements became effective June 9, 2003.  Compliance with the 
regulation was required by October 1, 2003 (31 CFR 103.121).  

The Comptroller of the Currency (OCC), in tandem with the Board of Governors 
of the Federal Reserve System, the Federal Deposit Insurance Corporation, the 
Office of Thrift Supervision, and the National Credit Union Administration, has 
developed examination procedures to evaluate national banks’ compliance with 
section 326 (attached).  The procedures were designed to help banks implement 
the new requirements and facilitate a consistent supervisory approach among the 
banking agencies.  

OCC examiners will use the procedures during Bank Secrecy Act/anti-money-
laundering examinations of national banks, and federal branches and agencies of 
foreign banks.  The examination procedures allow examiners to tailor the 
examination scope according to the reliability of the bank’s compliance 
management system and the level of risk assumed by the institution. 

The OCC plans to incorporate these procedures in an update to the Comptroller’s 
Handbook series.  Until the revised handbook is issued, examiners will use the 
attached procedures.  As other provisions of the act are implemented by 
regulation, additional procedures will be issued in a similar format.  OCC 
employees are available to assist banks with the new requirements and procedures, 
and questions may be directed to your supervisory office or to the Compliance 
Division at (202) 874-4428.



Ann F. Jaedicke
Deputy Comptroller for Compliance

Attachment: Examination Procedures
            [http://www.occ.treas.gov/ftp/bulletin/2004-34a.pdf]