What the OCC issued
On November 24, 2025, the OCC issued Bulletin 2025-37, which sets out Community Bank Procedures to supplement the FFIEC BSA/AML Examination Manual. The OCC says they are meant to reduce burden on community banks whose business models present low money laundering and terrorist financing risk. They apply to examinations beginning February 1, 2026, at OCC-supervised banks with up to $30 billion in assets.
The procedures are a baseline. Examiners add procedures from the FFIEC manual for higher-risk areas, so a bank with complex products or a changing risk profile should not expect a lighter exam just because of its size.
What changed
| Topic | What examiners may now do |
|---|---|
| Independent testing | Rely on testing they judge adequate, one section at a time. They can accept a bank’s currency transaction report testing, for example, while not relying on its suspicious activity monitoring testing. They look at whether the reports, scope and workpapers are complete, accurate and timely. |
| BSA officer and training | Carry forward the prior exam’s conclusions for one cycle if four things are true: the last findings were satisfactory, the bank’s risk profile, staffing and operations have not changed materially, independent testing had no material findings, and the current exam finds no problems in these areas. Conclusions cannot be carried forward for two exams in a row. |
| Transaction testing | Decide whether to test transactions at all, how much, or whether analytical review is enough. Lower-risk banks get limited testing, and areas are generally rotated from one exam to the next. |
| Documentation | The exam plan and workpapers have to show what was carried forward or relied on, so the bank can ask how its exam was scoped. |
Separately, in Bulletin 2025-38, the OCC stopped its annual money laundering risk data collection from community banks, ending a requirement that began in 2005.
What did not change
The bank still has to run a BSA program with all of its required parts, including independent testing, a BSA officer and training. The procedures change how examiners test a program, not what the program must contain. Relief is also at the examiner’s discretion. Nothing in the procedures promises a bank a lighter exam.
The procedures also apply only to banks the OCC supervises: national banks, federal savings associations, and federal branches and agencies of foreign banks. State-chartered banks examined by the FDIC, the Federal Reserve or a state agency are not covered by this bulletin.
What to do now
- Confirm who examines you. If your primary regulator is not the OCC, these procedures do not apply to your exam, though the same ideas may show up in how your examiners scope their work.
- Make your independent test easy to rely on. Because examiners can accept it section by section, have each part of the test clearly scoped, with workpapers that show what was sampled and how. A report that is vague about coverage is the one that gets retested.
- Keep a short record of changes. New products, staff turnover, system conversions and new customer types are what move a bank out of the carry-forward and limited-testing categories. If you can show the examiner that little has changed, you have the evidence they need.
- Close independent testing findings promptly. A material finding takes away the carry-forward for the BSA officer and training pillars.
- Do not cut your own testing or training because the exam may be lighter. The obligations in your program are unchanged, and your own review is what protects you if the examiner’s approach changes.
Our BSA audit team helps community banks test their programs independently and prepare documentation that examiners can rely on.