OCC’s August Actions Show Banking Missteps Come in All Sizes

Key Takeaways

• Enforcement Cuts Both Ways: The OCC targeted both institutions and individuals, showing its focus on systemic soundness and personal accountability.
• Trust Is Fragile: From capital planning failures at a small Illinois bank to embezzlement at household-name institutions, the actions highlight how weaknesses at any level can undermine confidence.
• Individual Accountability Matters: Lifetime bans for former employees reinforce that misconduct isn’t just a corporate failure, it carries career-ending consequences for those directly involved.
• Compliance Is a Moving Target: Anchorage Digital Bank’s successful termination of a cease-and-desist order underscores that regulators will close cases once institutions demonstrate genuine remediation.
• Consistency in Oversight: Whether dealing with crypto banks, regional lenders, or the largest financial institutions, the OCC’s actions reflect a consistent message that deficiencies will be identified, addressed, and, if necessary, punished.

Deep Dive

The Office of the Comptroller of the Currency (OCC) has published its latest round of enforcement actions, and the list makes for a telling snapshot of the different ways trust in the banking system can fray. On one end, a small Illinois bank is under pressure to fix fundamental weaknesses in capital and planning. On the other, a string of former tellers and managers from some of the country’s biggest banks have been banned from the industry for dipping into customer funds.

The Clinton, Illinois-based First National Bank & Trust agreed to a formal pact with regulators after examiners flagged problems tied to capital, liquidity, and strategic planning. Agreements like these are a warning shot to boards and executives: fix the weaknesses now, or expect sharper measures later.

But the real drama in this month’s enforcement slate lies in the human stories, the cases where individuals once entrusted with customer accounts instead treated them like personal piggy banks. A former teller in Trenton, New Jersey, embezzled more than $100,000 from PNC customers. In Brooklyn, a JPMorgan Chase employee processed fraudulent deposits and withdrawals worth nearly $200,000. On the West Coast, another Chase associate went even further, siphoning off around $440,000 in unauthorized withdrawals. TD Bank had two separate cases, one involving $120,000 in fraudulent activity in Connecticut and another tied to misuse of pandemic relief funds. Santander and First Financial branches weren’t spared either, with former employees misappropriating tens of thousands.

Each of those cases ends with an Order of Prohibition that effectively ends the individual’s banking career. The OCC is clear in its message—banks may have systems to detect misconduct, but it will not let individuals who abuse their position find another job in the sector.

The month’s actions weren’t only about crackdowns. Anchorage Digital Bank, the crypto-focused player based in South Dakota, managed to close the book on a 2022 cease-and-desist order tied to its Bank Secrecy Act and anti-money laundering program. For Anchorage, the termination signals progress in strengthening its compliance framework after an early stumble.

Taken together, August’s list captures the OCC’s broad remit of shoring up institutional soundness where planning and oversight fall short, and stepping in decisively when individuals betray the trust of customers. In banking, the failures may look different from Illinois to California, from vault thefts to faulty liquidity planning, but the message from the regulator is consistent in the fact that weaknesses, whether institutional or personal, will be called out and corrected.

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