OCC Announces Enforcement Actions for March 2025

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:

• Cease and Desist Order against 42 North Private Bank, Canton, Massachusetts, for unsafe or unsound practices, including those related to interest rate risk, strategic planning, capital, liquidity, and earnings. (Docket No. AA-ENF-2024-110). The OCC also terminated the bank’s cease and desist order dated March 30, 2017, which was replaced by the cease and desist order. (Docket No. AA-EC-2016-93)

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 Karla Vanderneut, former Assistant Branch Manager at an Earlville, New York, branch of NBT Bank, National Association, Norwich, New York, for using a customer’s account to make unauthorized cash withdrawals and debit card transactions totaling at least $16,000. (Docket No. AA-NE-2024-105)
• Order of Prohibition against Josiah Kennedy, former Vice President and Mortgage Loan Officer at Citizens Bank, N.A., Abilene, Texas, for making unauthorized draws on a customer’s construction loan and obtaining customers’ funds, totaling at least $59,000, for his personal benefit. (Docket No. AA-ENF-2025-01)

The OCC terminates enforcement actions when a bank has demonstrated compliance with all articles of an enforcement action; or when the OCC determines that articles deemed “not in compliance” have become outdated or irrelevant to the bank’s current circumstances; or when the OCC incorporates the articles deemed “not in compliance” into a new action. Termination actions include:

• Order terminating the Cease and Desist Order against ICICI Bank Limited, New York, New York, dated October 3, 2022 (Docket No. AA-ENF-2022-56). The order addressed violations of law and regulation related to the branch’s Bank Secrecy Act/Anti-Money Laundering compliance program. (Docket No. AA-ENF-2025-15)
• Order terminating the Cease and Desist Order against Wells Fargo Bank, N.A., Sioux Falls, South Dakota, dated September 9, 2021 (Docket No. AA-ENF-2021-29). The order addressed significant deficiencies related to the bank’s loss mitigation activities. (Docket No. AA-ENF-2025-19)

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

Related Link

• Enforcement Action Types