A Look at Two Recent OCC Bank Secrecy Act/Anti-Money Laundering Consent Orders: Lessons Learned

Summary: In our examination of two recent OCC BSA/AML consent orders, one with a bank and another with an in-house professional, we review the OCC’s allegations underlying the orders and how the OCC focuses on the core pillars of BSA/AML compliance when choosing to pursue enforcement. Topics discussed include takeaways for boards and management of financial institutions when accepting higher-risk customers, AML liability risk for individuals, and considerations in using third-party AML compliance advisors.