OCC Announces October Enforcement Actions, Targets Governance & BSA/AML Deficiencies

Key Takeaways

• First National Bank of Pasco Cited: The OCC entered a Formal Agreement with the Florida-based bank over unsafe or unsound practices tied to governance, strategic and capital planning, and BSA/AML deficiencies.
• Focus on Compliance and Oversight: The action reinforces the OCC’s emphasis on board accountability and the need for stronger internal controls across banks.
• No Individual Actions This Month: The agency reported no new enforcement actions against institution-affiliated parties (IAPs), such as directors or officers.
• Terminations Signal Progress: B2 Bank, California International Bank, and The National Iron Bank each had previous enforcement agreements terminated after addressing supervisory concerns.
• Ongoing Supervisory Priorities: The OCC continues to prioritize risk management, corporate governance, and BSA/AML compliance in its oversight of national banks and federal savings associations.

Deep Dive

The Office of the Comptroller of the Currency (OCC) released its list of enforcement actions for October 2025, highlighting continued regulatory focus on board oversight, corporate governance, and anti-money laundering compliance across the U.S. banking sector.

The most significant action came against First National Bank of Pasco, which entered into a Formal Agreement with the OCC after the agency found unsafe or unsound practices. According to the OCC, the deficiencies involved weak board oversight, inadequate strategic and capital planning, and lapses in Bank Secrecy Act and anti-money laundering (BSA/AML) risk management. The bank was also cited for violations related to suspicious activity reporting and due diligence programs for correspondent accounts tied to foreign financial institutions.

The OCC said enforcement actions like these are designed to compel bank directors and management to correct deficiencies and restore compliance. In this case, the agreement requires the bank to take corrective action to strengthen its risk management and governance frameworks.

While the OCC frequently issues actions against both institutions and individual bank officers or directors, the agency reported no new enforcement actions against institution-affiliated parties (IAPs) this month. Such actions typically target directors, officers, or employees found to have engaged in unsafe practices or breaches of fiduciary duty.

In addition to new enforcement actions, the OCC announced the termination of several older agreements, signaling progress among institutions previously under heightened scrutiny.

• B2 Bank National Association saw its 2023 Formal Agreement lifted after demonstrating compliance with corrective measures related to internal controls and management.
• California International Bank had two Formal Agreements terminated, one from 2021 and another from 2023, following improvements in capital, liquidity, and Bank Secrecy Act compliance.
• The National Iron Bank also had its 2023 agreement terminated after addressing concerns involving credit underwriting, capital and strategic planning, and BSA/AML risk management.

The OCC said it terminates enforcement actions when banks have satisfied the terms of the agreement, when certain provisions become outdated, or when those provisions are incorporated into new supervisory actions.

Although October’s list is shorter than in some months, it underscores the agency’s steady focus on governance, compliance, and risk management standards. Regulators have repeatedly emphasized that strong internal controls and board oversight remain the backbone of a safe and sound banking system, particularly as institutions continue to navigate economic uncertainty and evolving compliance expectations.

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