Joseph Otting, the US Comptroller of the Currency, recently outlined his regulatory agency's intentions for the near future in oral and written testimony to a senatorial committee.

The OCC employs nearly 4,000 people, two-thirds of whom are bank 'examiners' (on-site inspectors). On the subject of cybersecurity, the OCC is intent on scrutinising firms that provide online services to large banks: "Banks need to manage risks associated with using third parties through appropriate due diligence and risk oversight to ensure controls protecting the confidentiality, integrity, and availability of systems and data are maintained. Increasing consolidation among large technology service providers has created third-party concentration risk, in which a limited number of providers service large segments of the banking industry for key financial services. Operational events at these larger service providers could affect large parts of the financial industry, if not properly managed by the service providers and the banks that rely on their services. The OCC prioritize(s) supervisory activities related to these large service providers."

The Bank Secrecy Act 1970, which obliges all US banks to expend large parts of their turnover to help the Government in its quest to detect and stop money launderers, is imposing more and more onerous burdens on the financial sector with every year that passes. The OCC chief expresses this in a peculiar way: "The dynamic nature of money-laundering and terrorist-financing methods present challenges for banks to comply with the Bank Secrecy Act (BSA) requirements." Later on, he comments that new rules from the Government 'place burden' on financial institutions. Fortunately, he does not promise to impose any new burdens of his own but merely promises to supervise BSA/AML compliance more efficiently.

Indeed, at one point he echoes President Trump's disdain for red tape: "the process for complying with current BSA/AML laws and regulations has become inefficient and costly. Banks spend billions each year to comply with BSA/AML requirements. We need to reform the BSA/AML [sic] to be more efficient while improving the ability of the federal banking system and law enforcement to safeguard the nation’s financial system from criminals and terrorists." Otting proposes to do this by allowing regulators to schedule BSA/AML visits according to 'risk' and by working out ways to conduct associated visits in a more efficient manner. He wants the Government to make changes (he does not specify any, however) to the "threshold requiring mandatory reporting" of suspicious activity reports (SARs) and currency transaction reports and to simplify reporting forms and requirements. He also wants to offer bankers the 'holy grail' of AML work: true feedback from the police about how their SARs have led to arrests and confiscations. The obverse of this policy is his desire to explore the use of IT to "reduce reporting burden" and help the police obtain information from banks more quickly. He makes it plain, however, that none of these things are going to happen without the involvement of other regulatory bodies or their superintending owner, the US Treasury.

Otting wants to reduce all unnecessary burdens that banks that remain subject to the Volcker Rule might bear. In August last year, the OCC asked its regulatory charges for comments about how it could improve the regulation that puts the Volcker Rule into practice, especially by clarifying the provisions that prohibit and permit various activities. The agency also asked them how the federal regulatory agencies could enforce it more effectively without asking Congress to revise it. The results have yet to be seen.