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ARTICLE · 23 DECEMBER 2020

OCC Proposes Exemptions To Suspicious Activity Report Requirements

Hogan Lovells Cadwalader
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The OCC proposed a rule that would allow the agency to exempt national banks and federal saving associations from the OCC's suspicious activity reporting ("SAR") requirements.

United StatesFinance and Banking

The OCC proposed a rule that would allow the agency to exempt national banks and federal saving associations from the OCC's suspicious activity reporting ("SAR") requirements.

The OCC stated that the exemptive authority under this proposal is necessary as financial technology for the monitoring and reporting of financial crime continues to evolve. The proposed rule would permit the OCC to issue exemptions from OCC Rules 21.11 ("Suspicious Activity Report") and 163.180 ("Suspicious Activity Reports and other reports and statements"). Under the proposed rule, the OCC would be able to provide relief to national banks and federal savings associations that create innovative solutions for meeting Bank Secrecy Act requirements.

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