Comptroller of the Currency Curry's Speech before IIB Conference on AML

Comptroller of the Currency Thomas J. Curry gave a speech at the Institute of International Bankers' Annual Washington Conference discussing the increasing attention that the OCC has paid recently toward operational risk in large banks, including with respect to debt collection practices, trading operations, the Bank Secrecy Act ("BSA") and Anti-Money Laundering ("AML") compliance, and mortgage servicing. In particular, Comptroller Curry highlighted the operational risk that arises from a failure to maintain adequate BSA and AML compliance programs. By way of example, Comptroller Curry cited several "large, sophisticated banks" that have fallen short of BSA compliance in recent years. He went on to lay out several "areas of concern" for both regulators and banks with respect to AML/BSA compliance:

• Lack of compliance resources, especially in light of staff and/or resource reductions made after the financial crisis;
• International activities that some banks have not managed effectively, such as foreign correspondent banking, cross-border funds transfers, bulk crash repatriation, remote deposit capture and embassy banking;
• Third-party relationships and payment processors;
• New technologies and evolving payment activities, the compliance risks of which banks may not yet fully understand; and
• The potential migration of such high-risk activities to smaller banks that may lack the resources and personnel necessary to successfully manage the corresponding risk.

View speech in full here (links externally to OCC website).