Bank Secrecy Act/Anti-Money Laundering: Community Bank Minimum Bank Secrecy Act/Anti-Money Laundering Examination Procedures

Summary

This bulletin establishes the Community Bank Minimum Bank Secrecy Act (BSA/AML) Examination Procedures (Community Bank Procedures) for BSA/AML compliance examinations and provides guidance for Office of the Comptroller of the Currency (OCC) examiners on their application. The Community Bank Procedures, effective for examinations beginning February 1, 2026, reflect the OCC’s continued commitment to, and leadership on, efforts to improve the effectiveness and efficiency of the BSA/AML regime and reduce unnecessary burden on community banks.

Highlights

The Community Bank Procedures reduce burden on community banks by:

• Emphasizing examiner discretion to place reliance, as appropriate, on satisfactory independent testing to form a basis for conclusions for specific examination procedures.
• Allowing examiners to use discretion in carrying forward prior cycle examination conclusions for one examination cycle, for the Training and BSA Compliance Officer pillars, in instances where there have not been significant changes to the bank’s risk profile and in consideration of other relevant factors.
• Emphasizing examiner discretion to determine, as appropriate, whether and to what extent to perform transaction testing or whether it is appropriate to limit testing to analytical or other reviews.

Background

Since June 30, 2005, the Federal Financial Institutions Examination Council (FFIEC) has issued and updated the Bank Secrecy Act/Anti-Money Laundering Examination Manual (FFIEC BSA/AML Examination Manual) in an effort to ensure consistent examination procedures were applied when evaluating compliance with BSA regulatory requirements across all commercial banks, savings associations, and credit unions. While the FFIEC BSA/AML Manual is intended to guide examiners through an evaluation of any banking organization’s BSA/AML compliance program, the money laundering and terrorist financing (ML/TF) risks can vary significantly depending on the institution’s asset size or business lines. Applying these minimum examination procedures to all OCC-supervised institutions can be unduly burdensome, both on OCC examiner resources and on OCC-supervised institutions, when the banking organization’s business model presents low ML/TF risk.

As part of the OCC’s ongoing efforts to tailor its regulatory and supervisory frameworks to the size and risk profile of an institution, the OCC is issuing supplementary guidance for applying the FFIEC BSA/AML Examination Manual to all OCC-supervised community banks, referred to as the Community Bank Procedures. The Community Bank Procedures will reduce regulatory burden by tailoring examination activities appropriately to institutions that generally present low levels of ML/TF risks.

Further Information

Please contact Melissa Love, Deputy Comptroller for Compliance and Operational Risk, Office of the Chief National Bank Examiner, at (202) 649-6175.

James M. Gallagher
Senior Deputy Comptroller and Chief National Bank Examiner

Related Link

• Community Bank BSA/AML Examination Procedures (PDF)