On November 24, 2025, the OCC issued the Community Bank Minimum Bank Secrecy Act (BSA/AML) Examination Procedures for BSA/AML compliance examinations. The new Community Bank Procedures will become effective for examinations beginning February 1, 2026.
According to the OCC, the Community Bank Procedures reflect the OCC’s continued commitment to improve the effectiveness and efficiency of the BSA/AML regime and reduce unnecessary burden on community banks. The Procedures reduce burden on community banks by:
Emphasizing examiner discretion to rely on satisfactory independent testing for specific examination conclusions;
Allowing examiners to use prior cycle examination conclusions for one cycle in the Training and BSA Compliance Officer pillars when there are no significant changes in the bank’s risk profile, and considering relevant factors;
Emphasizing examiner discretion in deciding the extent of transaction testing or the appropriateness of limiting testing to analytical or other reviews.
The OCC’s announcement can be found here.
