OCC Announces Enforcement Actions for July 2024

WASHINGTON—The Office of the Comptroller of the Currency (OCC) today released enforcement actions taken against national banks and federal savings associations (banks), and individuals currently and formerly affiliated with banks the OCC supervises.

The OCC uses enforcement actions against banks to require the board of directors and management to take timely actions to correct the deficient practices or violations identified. Actions taken against banks are:

• Amended Cease and Desist Order and Civil Money Penalty against Citibank, N.A., Sioux Falls, South Dakota, for the failure to make sufficient and sustainable progress towards compliance with and violations of an October 7, 2020, Cease and Desist Order. The assessed civil money penalty is $75 million. (Amendment to Docket No. AA-EC-2020-64 and Docket No. AA-ENF-2024-51).
• Cease and Desist Order against CNB Bank & Trust, N.A., Carlinville, Illinois, for violations of 12 CFR 21.21 (Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance program), 31 CFR 1020.210 (Customer Due Diligence) and 1020.220 (Customer Identification Program), as well as unsafe or unsound practices relating to the bank’s BSA/AML compliance, and failure to correct previously reported BSA/AML compliance problems. (Docket No. AA-ENF-2024-47).
• Formal Agreement with Lincoln FSB of Nebraska, Lincoln, Nebraska, for unsafe or unsound practices, including those relating to strategic planning, liquidity risk management, contingency funding planning, interest rate risk management, and board oversight and corporate governance. (Docket No. AA-WE-2024-61).
• Cease and Desist Order against Summit National Bank, Hulett, Wyoming, for unsafe or unsound practices including those related to capital and strategic planning, liquidity risk management, transactions with affiliates, and the bank’s BSA/AML compliance program, and violations including of 12 CFR 21.21 (BSA/AML compliance program). (Docket No. AA-ENF-2024-31).

The OCC uses enforcement actions against an institution-affiliated party (IAP) to deter, encourage correction of, or prevent violations, unsafe or unsound practices, or breaches of fiduciary duty. Enforcement actions against IAPs reinforce the accountability of individuals for their conduct regarding the affairs of a bank. The term “institution-affiliated party,” or IAP, is defined in 12 USC 1813(u) and includes bank directors, officers, employees, and controlling shareholders. Orders of Prohibition prohibit an individual from any participation in the affairs of a bank or other institution as defined in 12 USC 1818(e)(7). Actions taken against IAPs are:

• Order of Prohibition against Cindy M. Flores, former Branch Operations Associate Manager at a Fargo, North Dakota, branch of Wells Fargo Bank, N.A., Sioux Falls, South Dakota, for misappropriating at least $47,600 by diverting funds from customer deposit accounts. (Docket No. AA-ENF-2024-42).
• Order of Prohibition against Randall David Ditzer, former Banking Center Team Lead Relationship Banker at a Prairie Village, Kansas, branch of BOKF, N.A., Tulsa, Oklahoma, for making unauthorized withdrawals from the accounts of an elderly bank customer and depositing the funds into his own accounts. (Docket No. AA-ENF-2024-50).
• Order of Prohibition against Andre Jackson, former Relationship Banker at a Kenmore, New York, branch of Bank of America N.A., Charlotte, North Carolina, for misappropriating at least $8,000 in cash from the bank. (Docket No. AA-ENF-2024-52).
• Order of Prohibition against Cordia Shedde McDonald, former Associate Banker at a New Rochelle, New York, branch of JPMorgan Chase Bank, N.A., Columbus, Ohio, for misappropriating at least $10,000 in cash from the bank. (Docker No. AA-ENF-2024-46).
• Order of Prohibition against Aaliyah Shaheed, former Digital Banking Representative for Varo Bank N.A., Draper, Utah, who worked remotely from Charlotte, North Carolina, for improperly accessing and modifying customer account information, which resulted in approximately $21,700 of fraudulent transfers. (Docket No. AA-ENF-2024-45).
• Order of Prohibition against Kathryn Thomure (now known as Kathryn Makler), former Business Banking Specialist at a Farmington, Missouri, branch of U.S. Bank, N.A., Cincinnati, Ohio, for making false representations on two Paycheck Protection Program loan applications to the U.S. Small Business Administration and receiving a loan for approximately $29,300. (Docket No. AA-ENF-2024-15).
• Order of Prohibition against Valeria Martinez Vazquez, former Branch Relationship Banker at Zions Bancorporation, N.A., Salt Lake City, Utah, for misappropriating approximately $11,100 from a customer’s account. (Docket No. AA-WE-2024-23)

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All OCC public enforcement actions taken since August 1989 are available for download by viewing the searchable enforcement actions database at https://apps.occ.gov/EASearch.

Related Link

• Enforcement Action Types