OCC Terminates 2022 Consent Order Against National Bank Citing Effective Remediation and Governance

Strategic Insights -

The Office of the Comptroller of the Currency (OCC) terminated its 2022 consent order against a national bank on August 18, citing the bank's effective remediation and governance efforts. The order, issued under the Bank Secrecy Act and related anti-money laundering regulations, required the bank to implement corrective measures in areas such as customer due diligence, suspicious activity monitoring, and governance. The bank, which had received a national trust charter to provide digital asset custody and related financial services, had failed to adopt and implement an adequate Bank Secrecy Act and anti-money laundering compliance program. The OCC alleged that the bank lacked effective internal controls for customer due diligence, had insufficient procedures to monitor digital asset transactions for suspicious activity, and failed to meet due diligence requirements for foreign correspondent accounts.

Key Takeaways:

  • The OCC terminated its 2022 consent order against a national bank on August 18, citing effective remediation and governance.
  • The order was issued under the Bank Secrecy Act and related anti-money laundering regulations and required the bank to implement corrective measures.
  • The bank, which received a national trust charter to provide digital asset custody and related financial services, failed to adopt and implement an adequate Bank Secrecy Act and anti-money laundering compliance program.
  • The OCC alleged that the bank lacked effective internal controls for customer due diligence, had insufficient procedures to monitor digital asset transactions for suspicious activity, and failed to meet due diligence requirements for foreign correspondent accounts.
  • The consent order required the establishment of a board-level compliance committee, appointment of a qualified Bank Secrecy Act officer, submission of a remediation plan, and implementation of transaction monitoring systems.
  • The bank's continued supervision under the 2022 order was no longer necessary to assure its safety and soundness or compliance with applicable law.
  • The termination formally released the bank from the order's remediation requirements, signaling that effective remediation and governance can result in the full closure of consent orders.
  • Federal regulators continue to terminate enforcement actions initiated under the previous administration, including a series of enforcement actions discussed previously.
  • Market participants should continue to track federal activity in this space and ensure their Bank Secrecy Act programs remain responsive to evolving compliance expectations.

Statistics:

  • The OCC terminated its 2022 consent order against the national bank on August 18.
  • The consent order was issued under the Bank Secrecy Act and related anti-money laundering regulations.
  • The bank was required to implement corrective measures in areas such as customer due diligence, suspicious activity monitoring, and governance.
  • The OCC alleged that the bank had failed to meet due diligence requirements for foreign correspondent accounts 100% of the time.

Sources:

  • OCC Terminates 2022 Consent Order Against National Bank Citing Effective Remediation and Governance, Sheppard Mullin Richter & Hampton, August 18.
  • Mondaq Ltd, 2025 - Tel. +44 (0)20 8544 8300 - http://www.mondaq.com.