OCC Announces Enforcement Actions for January 2025 and Updates to Enforcement Action Search Tool

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 also announced updates to its enforcement action search tool.

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 Bank of America, N.A., Charlotte, North Carolina, for violations and unsafe or unsound practices related to the bank's Bank Secrecy Act, anti-money laundering, and sanctions compliance programs. Refer to OCC News Release 2024-140. (Docket No. AA-ENF-2024-56)

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 and Order for Civil Money Penalty against Claudia Russ Anderson, former Community Bank Group Risk Officer at Wells Fargo Bank, N.A., Sioux Falls, South Dakota, for her failure to credibly challenge the bank's incentive compensation program, failure to institute effective controls to manage the risks posed by sales practices misconduct, and failure to escalate known or obvious risks related to sales practices misconduct, which contributed to the bank's systemic problems with sales practices misconduct that lasted until 2016, as well as for obstructing the OCC's examination of the bank. The assessed civil money penalty is $10 million. Refer to OCC News Release 2025-3. (Docket No. AA-EC-2019-81)

• Order of Prohibition against Brian Hernandez, former Financial Services Representative at a Queens, New York, branch of TD Bank, N.A., Wilmington, Delaware, for accessing the accounts of two elderly bank customers and making unauthorized ATM withdrawals totaling at least $187,000. (Docket No. AA-ENF-2024-86)

• Order of Prohibition against De'Anna Herrell, former Teller at an Atlanta, Georgia, branch of Wells Fargo Bank, N.A., Sioux Falls, South Dakota, for cashing a series of checks that she knew or had reason to know were fraudulent, resulting in a loss of at least $117,000 to the bank. (Docket No. AA-ENF-2024-41)

• Order to Cease and Desist and Order for Civil Money Penalty against David Julian, former Chief Auditor at Wells Fargo Bank, N.A., Sioux Falls, South Dakota, for his failure to plan and mange audit activity that would detect and document sales practices misconduct, failure to adequately escalate the sales practices misconduct, and failure to incorporate risk events in incentive compensation recommendations, which contributed to the bank's systemic sales practices misconduct that lasted until 2016. The assessed civil money penalty is $7 million. Refer to OCC News Release 2025-3. (Docket No. AA-EC-2019-71)

• Order to Cease and Desist and Order for Civil Money Penalty against Paul McLinko, former Executive Audit Director at Wells Fargo Bank, N.A., Sioux Falls, South Dakota, for his failure to plan and manage audit activity that would detect and document sales practices misconduct, failure to adequately escalate the sales practices misconduct, and failure to maintain independence from the Community Bank line of business, which contributed to the bank's systemic sales practices misconduct that lasted until 2016. The assessed civil money penalty is $1.5 million. Refer to OCC News Release 2025-3. (Docket No. AA-EC-2019-72)

• Order of Prohibition against Cassandra Meadows, former Lead Customer Service Representative at a Plainfield, Indiana, branch of Fifth Third Bank, N.A., Cincinnati, Ohio, for misappropriating at least $15,000 from the bank's vault and the accounts of three bank customers, including an elderly customer's account. (Docket No. AA-ENF-2024-97)

• Order of Prohibition against Isaiah Nicholson, former Customer Service Representative at Northfield Bank, Staten Island, New York, for misappropriating over $164,000 from two deceased bank customers' accounts. (Docket No. AA-NE-2024-74)

• Order of Prohibition against Nakyra Singletary, former Customer Service and Support Representative at PNC Bank, N.A., Wilmington, Delaware, for providing confidential bank customer information to a third-party not employed by the bank, resulting in the misuse of customer information, fraud against bank customers, and a loss of at least $47,000 to the bank. (Docket No. AA-ENF-2024-98)

• Order of Prohibition and Cease and Desist Order against David Wu, former Loan Officer at Sterling Bank and Trust, FSB, Southfield, Michigan, and current mortgage broker. While employed as a loan officer at Sterling, Wu did not disclose that he originated loans for clients of his closely held mortgage brokerage company. As a mortgage broker, Wu also used fraudulent means, including making false statements, concealing or otherwise not disclosing his role and fees, impersonating both applicants and their purported employers, and providing fraudulent or falsified documents, to cause Citizens Bank, N.A., Providence, Rhode Island, to originate mortgage loans for his clients and himself. (Docket No. AA-ENF-2024-109)

The OCC also updated its enforcement actions search tool to allow users to search for enforcement actions issued since 2012 by subject matter and to easily view subject matters covered in those actions. This update provides additional transparency into and search capability for the contents of the public enforcement action database. 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.

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Related Links

• Enforcement Action Types
• Enforcement Actions Search Tool