OCCFormal Agreementmedium

First National Bank of Pasco

In October 2025, the OCC announced a formal agreement with First National Bank of Pasco addressing unsafe banking practices. The action targeted deficiencies in BSA/AML risk management, suspicious activity reporting, and customer due diligence — all areas that are core compliance requirements for banks operating fintech or BaaS partnerships. Although the OCC did not explicitly connect the action to fintech partnerships, the nature of the cited failures mirrors common weaknesses found in sponsor bank examinations. The formal agreement likely requires the bank to implement remediation plans and enhanced compliance controls. This action is part of a broader trend of regulators scrutinizing BSA/AML programs at community and mid-size banks.

Verified from source: The OCC issued a Formal Agreement with First National Bank of Pasco, Dade City, Florida, for unsafe or unsound practices including board oversight and corporate governance, strategic and capital planning, BSA/AML risk management and suspicious activity reporting, and violations related to Suspicious Activity Reports and Due Diligence Programs for Correspondent Accounts for Foreign Financial Institutions (Docket No. AA-SO-2025-46).

Implications
  1. Signals continued OCC focus on BSA/AML deficiencies at smaller banks that may serve as BaaS or fintech partners
  2. Banks with fintech partnerships should proactively review SAR filing and CDD programs to avoid similar actions
  3. Formal agreements can restrict a bank's ability to onboard new fintech partners until remediation is complete
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