On September 4, the Fed announced the termination of two enforcement actions, both effective September 2. The first was a cease and desist order dated August 29, 2024, issued upon consent against a Texas state-chartered member bank after an examination purportedly identified significant deficiencies in the bank’s corporate governance and in its risk management and compliance with the BSA/AML related to foreign correspondent banking and virtual currency customers. The order had required the bank to, among other things, strengthen board oversight of BSA/AML and OFAC compliance, submit a revised BSA/AML compliance program, enhance its customer due diligence program, and improve its suspicious activity monitoring and reporting.

The second was a written agreement dated July 5, 2023, with two savings and loan holding companies that controlled a federal savings bank. The agreement had required the companies to: (i) serve as a “source of strength” to their subsidiary savings bank and support the savings bank in complying with an October 5, 2022, consent order alleging “unsafe or unsound practices, including those related to strategic planning and implementation, management and board oversight, audit, risk management, and mortgage banking activities”; (ii) conserve capital by prohibiting dividends, share repurchases, and other capital distributions without prior written approval; (iii) submit a capital plan; and (iv) comply with applicable laws and regulations regarding the appointment of directors and senior executive officers.