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Financial Services Law Insights and Observations

OCC issues consent order against digital asset bank for AML deficiencies

Bank Regulatory Federal Issues OCC Enforcement Bank Compliance Anti-Money Laundering Bank Secrecy Act SARs

On April 21, the OCC issued a consent order against the first federally-chartered bank focused on cryptocurrencies, just 15 months after granting the institution a national bank charter for purposes of taking custody of cryptocurrency. The consent order alleged failure to adopt and implement a compliance program that adequately covers required BSA/AML program elements. In January 2021, the OCC granted conditional approval to convert the bank’s charter to a national association with the “enforceable condition of approval” that the bank would, among other things, meet BSA/AML requirements.