2025 Regulatory Summit

Internal Use Only

Ag Bank 2Q2025 update: Risk Exposures Muted in Aggregate but Individual Banks Need Watching

Internal Use Only

BSA/AML Policy Priorities

Treasury Reform Initiatives

CSBS Potential Work Streams

• 2024 Program Rule (expect re-proposal). • Minimize impact of technical BSA violations on CAMELS “M” rating • Examiner training to reinforce true risk-based approach • CDD tied to new customer not new account • Clarify marijuana-related businesses definition and eliminate marijuana limited SARs • Remove MSBs from high-risk category

Tailor BSA/AML programs to the risk profile of the institution by improving info sharing on national priorities and deprioritizing other issues. Modernize CTR/SAR forms and leverage technology to ease burden. Focus on application of BSA/AML to digital assets.

• Streamline and create uniformity of filing requirements • Combine CTRs into SARs

• Guidance/best practices