The Office of the Comptroller of the Currency (OCC) has released its July 2026 monthly list of enforcement actions taken against national banks and federal savings associations. Among the actions announced was a Cease and Desist Order against United Texas Bank, Dallas, Texas, based on deficiencies identified in the institution's Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance program. The action serves as a timely reminder that BSA/AML compliance remains a top-tier supervisory priority for federal banking regulators.
The United Texas Bank order is consistent with a broader pattern of OCC enforcement activity emphasizing the importance of well-designed and effectively implemented BSA/AML frameworks. Regulators have continued to scrutinize the adequacy of institutions' compliance programs, risk assessments, and internal controls, and have shown a willingness to pursue formal enforcement measures where perceived weaknesses are not remediated through the ordinary supervisory process. National banks and federal savings associations of all sizes should read this latest action as a signal that examiners are actively probing the sufficiency of program governance, transaction monitoring capabilities, and the timeliness and quality of suspicious activity reporting.
For bank boards and senior leadership, the practical takeaway is to act proactively rather than reactively. Institutions should consider a fresh, top-to-bottom assessment of their BSA/AML compliance programs, with particular attention to governance and board oversight, the robustness of enterprise-wide and product-level risk assessments, the calibration and testing of transaction monitoring systems, the adequacy of staffing and expertise within the compliance function, the quality and cadence of employee training, and the processes supporting suspicious activity identification and reporting. Where gaps or weaknesses are identified, prompt and well-documented remediation efforts can meaningfully reduce the risk of formal enforcement action.
Institutions that have not recently engaged in an independent review of their BSA/AML programs may find that now is an opportune time to do so. Documenting a thoughtful, risk-based approach to compliance, and demonstrating credible remediation of any identified deficiencies, remains one of the most effective ways to manage supervisory expectations in the current environment.
This alert is provided for general informational purposes only and does not constitute legal advice. Clients facing specific BSA/AML compliance or enforcement issues should seek tailored counsel regarding their particular circumstances.