Citing ‘low level of money laundering,’ agency eases up on requirements for community banks

So-called national “community banks” received some easing of anti-money laundering (AML) requirements under a bulletin issued Monday by their federal regulator.

Separately, the Office of the Comptroller of the Currency (OCC) also issued a request for information (RFI) which it said is aimed at better understanding “how the challenges community banks face with core service providers and other essential third-party service providers affect community banks’ abilities to remain competitive.”

In the AML action, the OCC said it issued two bulletins. The first provides “supplementary guidance” tailoring the agency’s application of the BSA/AML examination procedures for all community banks based on the banks’ generally low levels of money laundering and terrorist financing risk. “This approach allows the OCC to consider a community bank’s risk profile rather than rely on minimum examination procedures that are unduly burdensome for banks and examiners and provide limited benefit.”

The second bulletin announces that the agency is discontinuing its Money Laundering Risk (MLR) system data collection. The system has, until now, been used by the OCC to, it said, understand, analyze, and assess money laundering (ML) and terrorist financing (TF) risks in among community banks. “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,” the agency said.

Together, OCC said, “these actions demonstrate the OCC’s efforts to improve the effectiveness and efficiency of BSA/AML compliance while reducing unnecessary burden on community banks.”

The new procedures are effective for exams beginning Feb. 1, the agency said.

For the RFI (also issued as a bulletin), the OCC said it “recognizes the vital role of community banks for the U.S. economy and seeks information on barriers community banks face in engaging with such service providers and actions the OCC could take to address these challenges.”

“The RFI focuses on ensuring that community banks can remain competitive in a rapidly evolving marketplace, and includes questions on the challenges community banks face related to contract negotiations and terms, fees, billing practices, oversight, due diligence, innovation, core conversions, data access and modernization, and interoperability issues,” the bulletin states. “It also includes questions on potential actions the OCC could take to address these challenges, including with respect to burden reduction related to supervisory practices, policies, and guidance (e.g., guidance on third-party risk management), as well as other potential agency initiatives.”

The agency notes that the RFI does not impose any obligations or define any rights. It also notes that the RFI is not an interpretation of any regulation or statute.

Comments will be due 60 days after publication in the Federal Register.

OCC Announces Additional Actions to Support Community Banks and Reduce Regulatory Burden

Bulletin 2025-37, “Bank Secrecy Act/Anti-Money Laundering: Community Bank Minimum Bank Secrecy Act/Anti-Money Laundering Examination Procedures

Bulletin 2025-38, “Bank Secrecy Act/Anti-Money Laundering: Discontinuation of Annual Money Laundering Risk System Data Collection

Bulletin 2025-39, “Bank Activities: Request for Information on Community Banks’ Engagement with Core Service Providers and Other Essential Third-Party Service Providers

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