OCCGeneralAugust 27, 2026

OCC Proposes Two-Tier Framework for Violations: Substantive vs. Technical

The OCC is proposing to split regulatory violations into 'substantive' and 'technical' categories to better calibrate supervisory responses, including when Matters Requiring Attention (MRAs) are issued. For banks and trust companies engaged in crypto or fintech activities, this could affect how examiners escalate findings related to BSA/AML, KYC, or digital asset compliance gaps. Comment period is open, giving institutions an opportunity to shape the final framework.

What to do

Review the proposed rule and assess how the substantive vs. technical violation distinction could affect your institution's existing MRA history and ongoing compliance programs; consider submitting a comment letter.

Who this affects

Bank / Credit UnionTrust Company

Does this affect your program?

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Source

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This radar entry is educational and does not constitute legal advice. Summaries are AI-assisted and grounded in the linked official source; always verify against the primary source and consult qualified legal counsel for jurisdiction-specific guidance.

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