On August 22, 2024, the Office of the Comptroller of the Currency (“OCC”) announced several enforcement actions that were launched in August 2024, including a formal agreement that it reached with Pennsylvania-based Slovenian S&LA of Franklin-Conemaugh to resolve allegations that the Bank was involved in “unsafe or unsound practices” with its Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”) internal controls, audit, and training. The OCC alleged that Slovenian S&LA’s practices violated federal regulations, including 12 CFR § 21.21 (BSA/AML compliance programs) and 31 CFR § 1020.210(a)(2)(v) (Customer Due Diligence). The OCC indicated that it found deficiencies in the company’s practices, “including those relating to strategic planning, succession planning, balance sheet management, [and] internal audits.”
As part of the Agreement, Slovenian S&LA must take several remedial measures, including, among other things, the appointment of a Compliance Committee to oversee the Bank’s compliance with the Agreement and the submission of a revised strategic plan/succession plan, a written internal audit program, and several “acceptable” BSA/AML programs (i.e., independent testing program, training program, officer and staffing program) to the Assistant Deputy Comptroller within 60 or 90 days of signing the Agreement.