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OCC Issues BSA/AML Consent Order Against Anchorage Digital Bank

On April 25, 2022, the Office of the Comptroller of the Currency (OCC) issued a consent order against Anchorage Digital Bank, N.A., citing deficiencies in its Bank Secrecy Act and anti-money laundering (BSA/AML) compliance programs. Anchorage Digital Bank had received its conditional national trust bank charter from the OCC in January 2021, making it the first federally chartered digital asset bank in the United States. The consent order, coming only 15 months after the charter grant, required Anchorage to remediate its compliance infrastructure.

The action underscores the heightened regulatory expectations placed on fintech and crypto firms that obtain bank charters. No financial penalties were publicly disclosed as part of the consent order. The enforcement action sent a signal to the broader BaaS and digital banking ecosystem about the importance of robust compliance frameworks, particularly for firms operating at the intersection of crypto custody and traditional banking.

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Implications
  • Signals that crypto-native banks face intense regulatory scrutiny even after obtaining federal charters
  • May deter fintech and crypto firms from pursuing bank charters without robust compliance infrastructure, affecting the BaaS landscape
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