The OCC conducts an annual data collection, known as the Money Laundering Risk (MLR) System, from community banks (national banks and federal savings associations), to assist OCC examiners in supervising Bank Secrecy Act (BSA) and sanctions compliance. The MLR system enhances the ability of examiners and bank management to identify and evaluate BSA/money laundering and Office of Foreign Asset Control (OFAC) sanctions risks associated with banks' products, services, customers, and locations.
The MLR is an important tool for the OCC's BSA/Anti-Money Laundering/OFAC supervision activities because it allows the agency to better identify those institutions, and areas within institutions, that pose heightened risk. This information assists us in allocating examination resources, improves examination scopes, and augments transaction testing capabilities. The MLR is critical in protecting financial institutions from potential abuse from money laundering or terrorist financing.
US Code:
12 USC 93a
Name of Law: National Bank Act
The change in burden was due to a combination of changes to the form and a reduction in the number of respondents.
Changes to the Form
The OCC updated the annual Risk Summary Form in 2012. The changes enhance the assessment process by requiring the reporting of products, services, and customers (PSCs) related to prepaid access or prepaid cards, a growth industry that is receiving increased attention from regulators, law enforcement, and Congress.
In addition, the Money Services Business (MSB) section of the form was modified to reflect changes in regulatory definitions. The form now includes MSB customers that are Providers of Prepaid Access and Sellers of Prepaid Access. All of these changes were made within the existing subject headers.
Change in Number of Respondents
The number of respondents decreased due to a nonmaterial change in 2011, which was overstated. The change added the thrift population transferred to the OCC via Dodd-Frank.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.