Highlights
A recent Office of the Comptroller of the Currency consent order
highlights the necessity of various controls, procedures,
monitoring, training and staffing in supporting for fintech,
digital asset, and financial service providers
Bank Secrecy Act/anti-money laundering programs must be
supported by sufficient customer due diligence
Such programs must also include sufficient procedures and
controls for monitoring and reporting suspicious activity
Further, these programs must staff and train a sufficient number
of personnel and qualified individuals in support
The Office of the Comptroller of the Currency (OCC) recently
issued a consent order relating to the adoption and implementation
of certain compliance program elements covering the Bank Secrecy
Act (BSA), as well as anti-money laundering (AML), combating the
financing of terrorism (CFT), and due diligence requirements. The
order highlights the important role sufficient controls,
procedures,
