March 18, 2022

OCC Amends SAR Regulations

The OCC adopted a final rule amending its regulations that require suspicious activity reports ("SARs") to clarify the agency's limited authority to issue exemptions to national banks and federal savings associations.

As outlined in the adopting release, the OCC has only limited authority to issue exemptions from SAR regulations, in contrast to FinCEN, which has broad exemptive authority.

The final rule will go into effect on May 1, 2022.

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