On September 19, 2024, the OCC released a list of recent enforcement actions against a federal savings bank, a national bank, and an individual affiliated with a national bank (an institution-affiliated party, or IAP).

In the action against the federal savings bank, the OCC determined the bank had engaged in unsafe or unsound practices associated with strategic planning, budgeting, succession planning, liquidity risk management, and interest rate risk management. The bank’s agreement with the OCC addressing these findings requires the bank to, among others, submit a strategic plan, a succession plan, and revised program documents addressing the bank’s liquidity risk management and interest rate risk management practices. In the action against the national bank, the OCC found deficiencies with the bank’s financial crimes risk management practices and anti-money laundering internal controls and requires the bank to take comprehensive corrective actions to enhance its BSA/AML compliance program, including, among others, establishing a compliance committee and submitting an action plan. In the consent order with the IAP, the OCC found that a former associate at a national bank was involved in a scheme to steal bank funds. The order prohibits the IAP from “participat[ing] in any manner in the conduct of [federal financial institutions].”