Office of the Comptroller of the Currency (“OCC”) examiners stated on Monday that they will no longer make recommendations on how banks can better comply with anti-money laundering (“AML”) regulations. Rather, the policy change designates all AML problems either as matters requiring attention or as violations of law. Thus, all AML problems could see enforcement actions if they are not addressed quickly.

Previously, in certain instances, the OCC provided recommendations to the banks it oversaw regarding ways to address their compliance with AML regulations. Although banks were expected to follow the recommendations, they did not face enforcement action for failing to do so.

At a meeting of the Association of Certified Anti-Money Laundering Specialists in Manhattan yesterday, James F. Vivenzio, Senior Counsel for Bank Secrecy Act/AML for the OCC, advised that in light of the policy-shift, banks should work closely with their examiners when they encounter an AML compliance issue in order to show that they are serious about fixing the problem. In turn, the examiners could give the banks more time to address any AML compliance issues.