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OCC reports on cybersecurity and financial system resilience

Privacy, Cyber Risk & Data Security OCC Bank Regulatory Bank Secrecy Act Artificial Intelligence

Privacy, Cyber Risk & Data Security

Recently, the OCC released its annual report on cybersecurity and financial system resilience, which describes its cybersecurity policies and procedures, including those adopted in accordance with the Federal Information Security Modernization Act. According to the report, cybersecurity and operational resilience are “top issues for the federal banking system.” The OCC also noted that it has implemented regulations and standards requiring banks to implement information security programs and protect confidential information. For example, the Interagency Guidelines Establishing Standards for Safety and Soundness Standards “require insured banks to have internal controls and information systems appropriate for the size of the institution and for the nature, scope, and risk of its activities and that provide for, among other requirements, effective risk assessment and adequate procedures to safeguard and manage assets.” OCC regulations also, among other things, require banks to file Suspicious Activity Reports when a known or suspected violation of federal law or a suspicious transaction related to illegal activity, or a violation of the Bank Secrecy Act is detected. In regard to examination manuals, the OCC also noted that it uses a risk-based supervision process to evaluate banks’ risk management, identify material and emerging concerns, and require banks to take corrective action when warranted. The report also discussed current and emerging cybersecurity and resilience threats to the banking sector, which include ransomware, account takeover, supply chain risks, and geopolitical threats. Additionally, the OCC noted that it “monitor[s] longer-term technology developments, which may affect cybersecurity and resilience in the future.” The use of artificial intelligence, including machine learning, is one such development that may impact cybersecurity, according to the OCC.

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