On October 16, the OCC announced enforcement actions for October, including one new formal agreement and four terminations of prior agreements.

The OCC entered into a formal agreement with a national bank in September after identifying unsafe or unsound practices related to BSA/AML compliance, suspicious activity reporting, and due diligence for correspondent accounts of foreign financial institutions. The agreement required the board to adopt a comprehensive governance program addressing policies related to risk management, strategic and capital planning, oversight of senior management, and conflicts of interest.

In addition, the bank must submit revised strategic and capital plans for OCC review; maintain a qualified BSA officer with sufficient independence and resources; and implement written BSA/AML programs for internal controls, customer due diligence, suspicious activity monitoring, and independent compliance testing. The agreement also established a compliance committee for oversight and mandated regular progress reporting to the board. Under the agreement, the OCC will review any proposed changes to the board or senior executive officers, and the bank must obtain OCC approval before making such appointments. No civil money penalty was assessed.

Apart from this agreement, the OCC’s announcement included four orders terminating formal agreements with three separate banks related to unsafe or unsound practices.