Each month, Quantivate provides our blog readers with access to the top attorney-generated compliance alert our customers receive. While there were 22 alerts and advisories to be aware of in April, the most pressing is that the Office of the Comptroller of the Currency (OCC) issued its final rule amending suspicious activity report (SAR) regulations.
On March 28, 2022, the OCC issued a final rule amending SAR regulations. The rule clarifies the OCC’s authority to issue exemptions from the requirements of those regulations based on a request from a national bank or federal savings association, including federal branches and agencies of foreign banks. The final rule takes effect on May 1, 2022.
The OCC’s final rule provides that, for any SAR regulation exemption request, the OCC will consider new criteria specified in the final rule, including consistency with the purposes of the Bank Secrecy Act and safe and sound banking. For exemption requests from the OCC’s SAR regulation that also would require an exemption from the SAR requirements established by the Financial Crimes Enforcement Network (FinCEN), a national bank or federal savings association would need to seek an exemption from both the OCC and FinCEN.
The final rule can be found below.
OCC Final Rule on SAR Exemptions
In April, Quantivate Compliance Management Services customers were made aware of 22 compliance alerts and advisories that will impact banks soon. In partnership with business law firm Farleigh Wada Witt, Quantivate customers can access integrated regulatory change alerts featuring executive summaries, in-depth documentation, and action plans.
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