11/3/25
Letter to OCC Regarding the Money Laundering Risk Assessment System
ICBA sent a letter to the OCC in response to its request for information on the Money Laundering Risk System. ICBA said the revisions to the MLR are unnecessary and place additional operational burdens on community banks without providing measurable benefits in combating money laundering or terrorist financing. ICBA also said it believes the estimated burden is significantly understated, and the consolidation of three fields is of no consequence.