The Office of the Comptroller of the Currency (OCC) is an independent bureau of the US Department of the Treasury, established by the National Bank Act of 1864, that charters, regulates, and supervises all national banks and federal savings associations operating in the United States, as well as the federally licensed branches and agencies of foreign banks. The OCC is one of the oldest federal financial regulators in the United States, and its origins are closely tied to the creation of the national banking system itself during the American Civil War, when Congress sought to establish a uniform national currency and a system of federally chartered banks to support it. The agency is headed by the Comptroller of the Currency, a Senate-confirmed official who also sits on the board of the Federal Deposit Insurance Corporation (FDIC), giving the OCC a direct role in the broader US bank regulatory architecture alongside the Federal Reserve and the FDIC.
In the AML and financial crime compliance context, the OCC plays a central supervisory role for the institutions under its jurisdiction — which include some of the largest banks in the United States, given that most major US national banks operate under an OCC charter rather than a state charter. While the Bank Secrecy Act (BSA) framework and its underlying rules are administered nationally by FinCEN, the OCC is one of the key federal banking agencies responsible for examining national banks for BSA/AML compliance, assessing the adequacy of their AML programmes, and taking supervisory or enforcement action where deficiencies are found. The OCC has the power to issue formal enforcement actions — including consent orders, civil money penalties, and, in serious cases, restrictions on a bank’s ability to grow or expand — and has been responsible for some of the largest AML-related penalties in US banking history, reflecting its supervisory responsibility for globally significant, systemically important banks. For compliance professionals at internationally active banks with a US national bank charter or federal branch presence, the OCC’s supervisory expectations — set out in its Comptroller’s Handbook and BSA/AML examination procedures — are a primary reference point alongside FinCEN’s regulatory requirements.
