News & Analysis as of

Compliance Risk Management Office of the Comptroller of the Currency

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Morrison & Foerster LLP

Crypto-Asset Safekeeping: What’s Involved If You’re a Bank (or if You Want to Be One)

On July 14, 2025, the federal banking agencies issued a joint statement to clarify regulatory expectations for banking organizations that provide or are considering providing safekeeping for crypto-assets (“Joint Statement”)....more

Sheppard Mullin Richter & Hampton LLP

Federal Banking Regulators Issue Joint Guidance on Crypto-Asset Safekeeping

On July 14, the OCC, Federal Reserve, and FDIC announced the release of a joint statement clarifying how existing laws and regulations apply to crypto-asset safekeeping services offered by banking organizations. The statement...more

Sheppard Mullin Richter & Hampton LLP

OCC Eliminates “Reputational Risk” Category from Bank Supervision Criteria 

On March 20, the OCC announced that it will no longer treat reputation risk as a standalone category in its supervision of national banks and federal savings associations. The decision marks a dramatic shift in the agency’s...more

Ballard Spahr LLP

Crypto Clarity: OCC’s New Guidelines Pave the Way for Banking Innovation

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On March 7, 2025, the Office of the Comptroller of the Currency (“OCC”) released Interpretive Letter 1183, marking a pivotal change in regulatory guidance for national banks and federal savings associations engaging in...more

K2 Integrity

Fiat Ramps Unlocked: Practical Tips For Banks And Crypto Firms

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Ask any centralized cryptocurrency firm to name one of their biggest priorities or challenges—and then count the number of times they mention bank partnerships. For crypto firms, the loss of, or failure to acquire, a bank...more

Cadwalader, Wickersham & Taft LLP

Business As Usual, October 2024 - OCC Releases 2025 Bank Supervision Operating Plan

The Office of the Comptroller of the Currency’s Committee on Bank Supervision sets the agency’s supervision objectives and priorities. On October 1, the Committee released the OCC’s Bank Supervision Operating Plan (the...more

Goodwin

10 Considerations for Fintechs Partnering with Community Banks

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As banking and technology become more integrated, banks are increasingly partnering with fintechs to expand their customer offerings. The rapid rise of these partnerships has generated questions for both banks and fintechs on...more

Sheppard Mullin Richter & Hampton LLP

South Dakota Lenders on Tight Deadline for BSA/AML Compliance

On January 12, South Dakota’s Division of Banking issued a mandate setting March 31, 2024 as the deadline for all South Dakota licensed money lenders and non-residential mortgage brokers to comply with their Bank Secrecy...more

NAVEX

How to Build a Good Risk Assessment Process

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Risk assessments are one of the most important tasks a compliance officer performs – and also one of the most confounding. How do you keep assessing your organization’s risks in a disciplined, methodical manner, when the...more

Holland & Knight LLP

Agency Guidelines Confirm That Climate-Related Financial Risk Is Real

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The U.S. Department of the Treasury's Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board) and the Federal Deposit Insurance Corp. (FDIC) (collectively, the Agencies) on...more

Moore & Van Allen PLLC

The Federal Reserve, FDIC and OCC Issue Final Guidance on Risk Management in Third-Party Relationships: Moore & Van Allen

On June 6, 2023, the Board of Governors of the Federal Reserve System (the Federal Reserve), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC, and collectively with the...more

Venable LLP

Bank Provider of BaaS Dinged by OCC; Blueprint for Fintech Partnerships?

Venable LLP on

​​​​​​​A recent action by the Office of the Comptroller of the Currency (OCC) highlights how banks need to ensure that they have robust compliance programs for managing risks posed by their banking as a service (BaaS)...more

Latham & Watkins LLP

Federal Reserve Issues Cryptoasset Engagement “Rules of the Road” for Its Supervised Banking Organizations

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The Federal Reserve is taking measured steps to better understand the types of cryptoasset-related activities contemplated by its supervised banking organizations. On August 16, 2022, the Board of Governors of the...more

Mitratech Holdings, Inc

Operational Resilience for Financial Institutions: Will You Be Ready?

The UK’s Operational Resilience Framework - Financial services regulators have been focusing on the robustness of their chartered institutions for many years. In 2020 the Federal Reserve highlighted the need for enhanced...more

Mitratech Holdings, Inc

OCC Puts Quantitative Models in Scope for Regulatory Compliance

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The US Office of the Comptroller of the Currency (OCC), a primary US banking regulator, has recently published its Model Risk Management (MRM) Handbook. It details how the OCC expects its chartered banks to manage their MRM...more

Eversheds Sutherland (US) LLP

Federal Banking Regulators Shine Light Again on Third-Party Risk Management

Federal banking regulators have again demonstrated their focus on bank oversight and management of risk from third party relationships through a series of guidance and proposed guidance published in the third quarter of 2021....more

The Volkov Law Group

Citigroup Fined $400 Million by Banking Regulators for Risk and Compliance Control Deficiencies

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Banking regulators, the Office of Comptroller of the Currency and the Federal Reserve, recently collected a $400 million civil penalty against Citigroup for long-standing deficiencies in its enterprise risk management,...more

Skadden, Arps, Slate, Meagher & Flom LLP

New UDAAP Guidance Is Relevant to OCC-Regulated and Nonregulated Institutions Alike

In late June 2020, the Office of the Comptroller of the Currency issued a new booklet on “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices” (the UDAAP booklet), setting forth a...more

Society of Corporate Compliance and Ethics...

Capital One fined for inadequate data controls

Report on Supply Chain Compliance 3, no. 16 (August 20, 2020) - The Office of the Comptroller of the Currency fined Capital One USD 80 million for inadequate data controls leading to a 2019 data breach and for failing to fix...more

Katten Muchin Rosenman LLP

Bridging The Week - September 2019

A clearing organization for futures and securities was sanctioned US $20 million in aggregate by the Commodity Futures Trading Commission and the Securities and Exchange Commission for allegedly not having and following...more

WilmerHale

OCC Revises CMP Policy

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For the first time in over twenty years, the Office of the Comptroller of the Currency (OCC) has formally changed its policy governing civil money penalties (CMP) against national banks, federal savings associations, federal...more

Orrick, Herrington & Sutcliffe LLP

New Guidance for Financial Institution Directors and Officers In Cybersecurity Preparedness

Earlier this summer, the Federal Financial Institutions Examination Council (FFIEC) released its highly anticipated Cybersecurity Assessment Tool (Assessment), which is designed to assist financial institutions in identifying...more

Morrison & Foerster LLP

Dodd-Frank at 4: Where do we go from here?

Where do we go from here? As we mark another milestone in regulatory reform with the fourth anniversary of the enactment of the Dodd-Frank Act, it strikes us that although most studies required to be undertaken by the Act...more

Goodwin

OCC Issues Final Guidelines Calling for Heightened Standards for Governance and Risk Management of Large Financial Institutions

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The OCC issued final guidelines (the “Final Guidelines”) that call for strengthened governance and risk management practices at the following categories of large financial institutions with $50 billion or more in average...more

Ballard Spahr LLP

OCC Releases Guidelines on 'Heightened Expectations' for Large National Banks and Savings Associations

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The Office of the Comptroller of the Currency (OCC) recently released proposed amendments to its Part 30 regulations, which reflect the agency's "heightened expectations" for large banks. That release, styled as an "Interim...more

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