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61 locations during late 1985 and reached nearly 6,000 people.

In addition, we have provided speakers to participate in meetings before banking and law enforcement community groups to

discuss BSA and other enforcement issues.

Moreover, our BSA

specialists and attorneys across the country and here in Washington respond to inquiries on a daily basis.

Fourth, we have participated in various interagency task forces

and working groups and have continued to assist the law enforcement community whenever possible in their enforcement efforts. We were, for instance, instrumental in establishing a

working group consisting of senior officials from our office,

the Justice Department's Criminal Division, the FBI, and each


of the major financial institutions regulatory agencies. group's purpose was to improve the Federal Government's effectiveness in fighting crime in the nation's financial institutions.

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implemented for use by each of the supervisory agencies and all financial institutions. The form has promoted consistency in

the reporting of suspected criminal offenses and has provided

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Justice with a better means of tracking criminal referrals.

Agreement was reached that the regulatory agencies would each

adopt regulations or guidelines similar to OCC's Interpretive

Ruling (12 C.F.R. S 7.5225), which requires banks to report any

suspected criminal activity.

We have also proposed amendments

to improve our rule.

In addition, the group improved communications by identifying

points of contact in each agency on the national and local

level, thus establishing a network of individuals responsible

for coordinating referrals and prosecutions. Specifically at Occ, District Counsel have been required to establish and maintain contact with individual United States Attorneys' Offices, FBI offices and strike forces for the purpose of coordinating criminal enforcement matters.

Moreover, to accelerate our response to law enforcement

inquiries, we have formally delegated additional authority to

the District Offices to respond and provide information

directly. Similarly, we have worked with trade groups and

individual representatives of the banking community to

establish banking community contacts for the swift handling of

problems in this area.

OCC also has enhanced its Enforcement and Compliance

Information System (ECIS) to track criminal referrals and

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disciplinary actions taken by the OCC or the other agencies

against bank officials.

As a result, we

are now able to use

the system in our background investigations of organizers of

new banks and of change in control applicants.

The working group also recommended that a joint training course

be developed to cross train FBI agents and examiners.


agencies and the Department of Justice each committed resources, and a formal training course was developed. A series of joint training sessions has since been held both at the FBI Academy at Quantico and at selected sites around the


In addition to our work with the Department of Justice working group, OCC participated actively in efforts specifically focused on improving BSA enforcement. We worked with Treasury

and other financial institutions regulators to revise the

uniform BSA examination procedures.

These revisions, which are

presently undergoing a final review at Treasury, should be

implemented in the near future.

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We also vigorously supported the work of the IRS/Financial

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Despite this progress, we believe that we must continue to do


To ensure that the progress of the last year is not

lost, on-going training and industry awareness efforts are critical. In light of the Deficit Reduction Act of 1985

(Gramm-Rudman-Hollings), however, although OCC remains

committed to such efforts, we may not be able to maintain the

same pace during 1986.

Resources have been severely strained,

and it has been necessary to make across-the-board reductions

in training expenditures.

Moreover, District training

conferences and OCC attendance at public conferences and

seminars, which have been valuable vehicles for sharing

information on BSA and other important topics, have been

cancelled or reduced.

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In addition to on-going training and education efforts, we

believe that progress is essential in two critical areas if

gains are to be made in the Federal Government's efforts to

ensure compliance with the BSA.

These areas are (1) increased

coordination among the agencies with compliance and enforcement responsibilities and (2) more effective use of available data

for targeting compliance and enforcement efforts.

Increased Interagency Coordination

We have great faith in the benefits which can be derived from

the interagency working group process.

As discussed above, the

Justice Department's working group, in which we are a very

active participant, has proven how effectively the bank

regulators can work together with the law enforcement


We believe this experience can be used as

a model

for success in the BSA area, and as an active participant in the IRS/Financial Institutions Regulatory Working Group, we are

looking forward to the same accomplishments in the BSA area.

Improved Targeting

Improved communications and utilization of available BSA and other financial data could, we believe, significantly increase the return on our enforcement and compliance resources. clearly, neither occ nor any of the other financial

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