OMBOffice of Management and Budget
An office within the Executive Office of the President that prepares the federal budget and oversees how federal agencies implement policy, including how they manage information technology. OMB issues the government-wide guidance on how federal agencies use and acquire artificial intelligence.
Why it matters
OMB rules apply to federal agencies rather than to private banks, but they matter to AML teams in two ways: agencies such as Treasury and the banking regulators follow them when they use AI themselves, and they signal what US authorities consider responsible AI governance.
OMB Memorandum M-25-21, issued in April 2025, replaced the 2024 guidance (M-24-10). It requires agencies to appoint Chief AI Officers, publish AI strategies, and apply minimum risk management practices to high-impact AI, including pre-deployment testing, impact assessments, ongoing monitoring and human oversight. A companion memo, M-25-22, covers AI procurement, and M-26-04 (December 2025) sets requirements for large language models that agencies buy.
These practices mirror what bank supervisors expect under model risk management: documented testing, explainable outputs and accountable human decisions.
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