Unknown Sponsor Bank
The U.S. Office of the Comptroller of the Currency (OCC) recently entered a consent order with a fintech partner bank for failures in its Bank Secrecy Act / Anti-Money Laundering (BSA/AML) compliance program. The OCC found the bank's program did not meet required standards in areas including risk assessment, customer due diligence, and transaction monitoring. The action is primarily corrective, focused on governance, systems, and oversight remediation, with no civil money penalty amount clearly specified. The enforcement is characterized as a warning to the broader banking-as-a-service (BaaS) and fintech sponsor bank sector, reinforcing that the chartered bank remains fully responsible for BSA/AML compliance even when operating numerous fintech programs.
Verified from source: The OCC entered a consent order with a fintech partner bank over BSA/AML compliance deficiencies, including deficient suspicious activity alerting, insufficient customer due diligence, failure to identify correspondent accounts with foreign financial institutions, and weak internal auditing. No monetary penalty was imposed.
- Reinforces that sponsor banks bear full BSA/AML compliance responsibility regardless of fintech partnerships
- Signals heightened OCC scrutiny of BaaS and fintech partner bank compliance programs
- May prompt other BaaS banks to proactively review and strengthen their BSA/AML frameworks
- BlogThe WBK Firm