OCC Semiannual Risk Perspectives Spring 2019
The Office of the Comptroller of the Currency
"While overall trends have been positive, the BSA/AML-related deficiencies identified by the OCC stem from three primary causes:
* inadequate customer due diligence and enhanced due diligence,
* insufficient customer risk identification, and,
* ineffective processes related to suspicious activity monitoring and reporting, including the timeliness and accuracy of Suspicious Activity Report filings.
Talent acquisition and staff retention to manage BSA/AML compliance programs and associated operations present ongoing challenges, particularly at smaller regional and community banks."