iKinetiq RegWatch - OCC Enforcement Actions for July

The Office of the Comptroller of the Currency (OCC) has announced its July enforcement actions against national banks and federal savings associations the OCC supervises. The OCC uses enforcement actions to require the institutions to take timely actions to correct the deficient practices or violations identified. This month's actions include:

CNB Bank & Trust, N.A. (Carlinville, IL)

• The OCC entered into a Consent Order with CNB for violations of the Bank Secrecy Act and Anti-Money Laundering (BSA/AML) compliance.  
• CNB failed to develop and maintain an adequate BSA/AML compliance program, including specifically, deficiencies in their internal controls, independent testing, and training.  
• CNB also failed to correct previously identified deficiencies in its BSA/AML compliance program.
• CNB is required to submit a BSA/AML Action Plan detailing remedial actions to achieve compliance with the BSA and related regulations.

Lincoln FSB of Nebraska (Lincoln, Nebraska)

• Lincoln entered into a Formal Agreement with the OCC after the OCC found unsafe or unsound practices related to strategic planning, liquidity risk management, contingency funding planning, interest rate risk management, board oversight, and corporate governance.
• Lincoln must submit a strategic plan, liquidity risk management program, and contingency funding plan for the OCC to review and approve.
• Lincoln's compliance committee must monitor and oversee its adherence to the agreement, meeting at least quarterly and submitting progress reports to the board.

Summit National Bank, (Hulett, Wyoming)

• The OCC issued a Consent Order due to unsafe practices and deficiencies in the BSA/AML compliance program.
• The order requires the establishment of a Compliance Committee, the development of a Strategic and Capital Plan, and the implementation of a Liquidity Risk Management Program.
• Summit must maintain accurate records, comply with the Office of Foreign Assets Control (OFAC) regulations, and ensure effective BSA/AML governance.
• The order mandates higher capital minimums and corrective actions to address the identified deficiencies.

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