OCCFormal Agreementhigh

Wells Fargo

San Francisco, California

Wells Fargo and the OCC signed a formal agreement on Sep 12, 2024, citing deficiencies in the bank's risk management, suspicious activity reporting, currency transaction reporting, and beneficial ownership and client identification programs. Under the agreement, Sioux Falls, South Dakota-headquartered Wells Fargo must submit a remedial action plan within 120 days to achieve and sustain compliance with the Bank Secrecy Act and sanctions administered by the Office of Foreign Assets Control. S.

bank by assets. The agreement does not carry a monetary penalty.

Implications
  1. Reinforces importance of BSA/AML and OFAC compliance for all banks, including those with fintech partnerships
  2. May prompt BaaS and sponsor banks to review and strengthen their own BSA and sanctions compliance programs
  3. Signals continued OCC willingness to pursue formal enforcement actions for compliance failures
Source
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