On August 22, the OCC released a list of recent enforcement actions against national banks, federal savings associations, and individuals affiliated with such entities (defined as institution-affiliated parties, or IAPs). The OCC listed twelve recent actions: four formal agreements with banks, six actions against IAPs, and two orders terminating preexisting formal agreements.
With respect to the formal agreements with banks, all four involved unsafe and unsound practices, including those related to strategic planning, board oversight, liquidity risk management, and interest rate risk management. One agreement involved internal BSA/AML controls, audit, and training, with another agreement involving an affiliate-transaction violation. The six actions against IAPs involved misappropriation. With respect to the termination orders, one involved a prior formal agreement relating to credit risk management, insider activities, and exception reporting, and the other involved BSA risk management and strategic planning. More information on the OCC’s enforcement action types can be found here.