OCC 2003-43	
OCC Bulletin

Subject:      Bank Secrecy Act
Description:  Examination Procedures

Date:         October 20, 2003
 
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).  Regulations implementing sections 313 and 319 
of the act became effective October 28, 2002, (31 CFR 103.177 and 
31 CFR 103.185) and a regulation implementing section 314 of the act 
became effective September 26, 2002, (31 CFR 103.100 and 
31 CFR 103.110).  These regulations address new provisions relating 
to foreign correspondent accounts and also require that certain 
records be maintained and made available to regulatory and law 
enforcement officials.  These regulations also address the process 
by which the government shares information with financial 
institutions about suspected money launderers and terrorists and the 
ways in which financial institutions may share such information with 
one another.  

The Comptroller of the Currency (OCC) in consultation with the Board 
of Governors of the Federal Reserve System, the Federal Deposit 
Insurance Corporation, Office of Thrift Supervision, and the 
National Credit Union Administration has developed examination 
procedures to evaluate national banks’ compliance with these new 
requirements (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.



David G. Hammaker
Deputy Comptroller for Compliance

Attachment: [http://www.occ.treas.gov/ftp/bulletin/2003-43a.pdf]