OCC Bulletin 2025-38 | November 24, 2025

Bank Secrecy Act/Anti-Money Laundering: Discontinuation of Annual Money Laundering Risk System Data Collection

To

Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties

Summary

The Office of the Comptroller of the Currency (OCC) will no longer annually collect information from community banks¹ through the Money Laundering Risk (MLR) System.

Note for Community Banks

This guidance is applicable to all community banks.

Highlights

Effective immediately, the OCC is discontinuing the annual mandatory data collection from community banks under the MLR System.
Historically, the OCC has utilized the MLR System to understand, analyze, and assess the money laundering (ML) and terrorist financing (TF) risks in the OCC’s community bank portfolio.
The OCC has determined that there are alternative, less burdensome means of assessing community banks’ ML/TF risks and, therefore, believes the MLR System is no longer necessary.
These actions build upon the OCC’s continued efforts to tailor its regulatory and supervisory frameworks to minimize burden for its regulated institutions and promote economic growth.

Background

Since 2005, the OCC has conducted an annual data collection, known as the MLR System, from community banks to assist OCC examiners in supervising Bank Secrecy Act (BSA) and sanctions compliance. Under the MLR System, community banks provide the OCC with information on certain products, services, and customers (PSC) that potentially raise elevated ML/TF concerns. The OCC has historically used collected MLR information to inform supervisory activities, including examination scoping, planning, and transaction testing.

As part of the OCC’s ongoing commitment to appropriate risk-based supervision, the OCC has recently taken steps to ensure that the agency’s bank supervision process is tailored to reflect the generally lower risk posed by community banking activities.² Consistent with this ongoing commitment, the OCC is discontinuing the annual MLR System data collection, which imposed a regulatory burden exclusively on community banks. The OCC believes that the MLR System is no longer necessary and that the OCC can obtain appropriate information on the ML/TF risks of the community bank portfolio in a less burdensome manner, including more tailored requests for information in connection with on-site examination activities. This decision is informed by the OCC’s demonstrated ability to adequately perform BSA-related examination activities for its Large and Global Financial Institutions and Regional and Midsize Financial Institutions groups, which are not required to participate in the MLR System’s annual data collection. The OCC also considered that the MLR System is unique to the OCC’s supervision of community banks, so discontinuing the MLR System would harmonize BSA-related data collection processes across the federal banking agencies.

The OCC will continue to expect community banks to adequately understand the ML/TF risks of their business operations and to comply with applicable laws and regulations, including those issued pursuant to the BSA. Community banks may continue to utilize the OCC’s previously identified PSCs when evaluating the ML/TF risks of their business operations, if relevant. The OCC, however, will no longer prescriptively require community banks to categorize their products, services, and customers to comply with the PSC data collection requirements of the MLR System.

Further Information

Please contact the Office of the Chief National Bank Examiner at 202-649-5420.

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