US OCC Issues First-Ever AI Guidance for Bank Examiners

The US Office of the Comptroller of the Currency (OCC) has issued its first-ever guidance outlining how bank examiners should assess the use of Artificial Intelligence (AI) by financial institutions. The framework calls for AI applications to be evaluated within existing risk-management structures rather than treated as a separate category of risk.

Under the guidance, examiners are expected to consider how banks deploy AI, alongside their size and operational complexity. The OCC has also emphasised assessing the potential consequences of AI-driven errors rather than focusing solely on the sophistication of the models being used.

For instance, AI agents authorised to initiate financial transactions may require stricter controls than advanced models used for internal purposes. Higher-risk applications may warrant limitations on autonomy and greater human oversight.

Although the guidance is not legally binding, it is expected to influence supervisory practices, reinforcing regulatory focus on AI governance, accountability and operational risk management across the banking sector.