The Office of the Comptroller of the Currency issued a consent cease-and-desist order against CNB Bank & Trust, N.A., a community bank headquartered in Carlinville, Illinois, in an order made public on 18 July 2024, for violations of Bank Secrecy Act and anti-money-laundering compliance requirements. The order, designated Docket No. AA-ENF-2024-47, sets out a range of deficiencies across the bank's BSA/AML compliance programme and requires the institution to undertake specific remediation steps within defined timeframes.
The OCC found that CNB Bank & Trust had engaged in unsafe or unsound practices across several core elements of its BSA/AML compliance framework. The regulator identified deficiencies in the bank's internal controls, in the designation of a suitably qualified BSA Compliance Officer, in the conduct of independent testing of the compliance programme, and in staff training on anti-money-laundering obligations. The OCC also found that the bank had failed to correct BSA/AML compliance problems previously brought to its attention by the regulator.
REGULATORY PROVISIONS VIOLATED
The consent order cites violations of three specific regulatory provisions: 12 CFR 21.21, which governs the requirements for a national bank's BSA/AML compliance programme; 31 CFR 1020.210, which sets out the standards for Customer Due Diligence; and 31 CFR 1020.220, which covers Customer Identification Programme requirements.
Under 12 U.S.C. § 1818(s)(3)(B), the regulator must issue a cease-and-desist order when a bank has failed to correct a problem with its BSA compliance programme that the regulator previously reported to it.
REMEDIATION
The bank will be expected to report progress to its supervising examiner on a schedule set out within the order.