OCC Launches 2025 with Stringent Enforcement Actions & A Call for Accountability

The Office of the Comptroller of the Currency (OCC) has begun the year by unveiling a sweeping set of enforcement actions aimed at holding banks and their personnel accountable. January’s slate includes hefty penalties, prohibitions, and stern warnings for institutions and individuals alike. Beyond the headlines, it’s a sharp reminder of the regulator’s ongoing commitment to rooting out misconduct at every level of the financial sector.

One notable target is Bank of America, which received a Cease and Desist Order for serious lapses in its compliance programs, including violations of the Bank Secrecy Act, anti-money laundering (AML) regulations, and sanctions requirements. Such deficiencies aren’t mere technical oversights—they point to systemic issues that can undermine trust in the broader financial system. While the bank has been ordered to address these shortcomings, the broader implications signal a growing intolerance for gaps in high-stakes compliance areas.

Personal Responsibility in Financial Misconduct

The OCC also turned its attention to individual accountability, zeroing in on former executives tied to one of banking’s most infamous scandals. Among them, Claudia Russ Anderson, who once served as Wells Fargo’s Community Bank Group Risk Officer, faces a $10 million penalty and a prohibition order. Her failure to manage risks associated with incentive compensation practices and her obstruction of regulatory examinations underscore the regulator’s focus on personal responsibility in systemic failures.

This theme of individual accountability extended to other former Wells Fargo leaders. David Julian, the bank’s former Chief Auditor, and Paul McLinko, a former Executive Audit Director, were penalized $7 million and $1.5 million respectively. Both were cited for failing to adequately address sales practices misconduct that plagued the institution for years. These cases emphasize that senior leadership’s inaction can have long-lasting consequences—not just for their careers but for the reputations of the organizations they served.

Not all enforcement actions, however, revolve around high-level executives. The OCC also addressed misconduct at the branch level, with actions against employees who abused their positions of trust. In one case, Brian Hernandez, formerly of TD Bank, withdrew $187,000 in unauthorized transactions from elderly customers’ accounts. Similar breaches of trust were seen at institutions like Fifth Third Bank and PNC Bank, where employees misappropriated funds or shared customer information, resulting in financial losses and further erosion of public confidence.

Among the more elaborate schemes highlighted was that of David Wu, a former loan officer at Sterling Bank. Wu’s activities went beyond routine misconduct—he leveraged fraudulent documents, impersonated clients, and concealed his conflicts of interest to secure mortgages under false pretenses. His actions demonstrate how unchecked behavior at any level can escalate into significant regulatory and reputational risks.

Raising the Bar for Compliance & Accountability

These enforcement actions are a clear signal that regulators are sharpening their focus on accountability at every level. The OCC’s actions highlight the critical importance of addressing systemic risks proactively, not reactively, and ensuring compliance programs are more than just check-the-box exercises.

Institutions must take a hard look at their governance structures, not only to mitigate risks but also to build resilience in the face of growing regulatory scrutiny. Compliance isn’t just about avoiding penalties, it’s about fostering trust, protecting stakeholders, and demonstrating that an institution is prepared to uphold its responsibilities—even under a magnifying glass.

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