OCC’s Record-Breaking BSA/AML Enforcement

In October alone, the OCC issued more than $1 billion in fines for Bank Secrecy Act and anti-money laundering (BSA/AML) violations, including a record $750 million penalty against a single bank. The enforcement actions cited failures to address systemic weaknesses, conduct adequate internal audits, train staff, and act on prior examiner criticism. The institutions involved were large, but the standards set in cases like these often become the benchmark examiners apply to banks of every size. Recording on location at the OCC’s Philadelphia field office, Polsinelli shareholder and former OCC enforcement lawyer Travis Nelson explains what these actions signal for smaller institutions and what banks can do now to keep their BSA/AML programs aligned with examiner expectations.