The Office of the Comptroller of the Currency entered into a formal agreement with First National Bank & Trust Company, a federally chartered bank based in Clinton, Illinois, operating under charter number 14851, in August 2025. The agreement requires the institution to remediate identified deficiencies in its Bank Secrecy Act and anti-money laundering compliance programme and to implement a range of improvements to its internal controls for managing financial crime risk. A formal agreement is one of the OCC's primary enforcement tools and carries binding legal force on the bank.

The OCC's action followed a supervisory review that identified weaknesses in First National Bank & Trust's compliance management system and its internal controls for anti-money laundering and counter-terrorism financing risk. The regulator determined that the bank's existing arrangements were not adequate to identify, assess, and manage the financial crime risks associated with its customer base and the types and volume of transactions it processes, and that a formal corrective action instrument was therefore warranted to compel the necessary improvements.

REQUIRED PROGRAMME IMPROVEMENTS

Under the terms of the formal agreement, First National Bank & Trust is required to establish a comprehensive BSA/AML compliance programme that addresses the deficiencies documented by the OCC. A central element of this requirement is the enhancement of customer due diligence procedures, which must ensure that the bank collects and analyses sufficient information about the nature and purpose of its customer relationships to enable it to identify transactions that deviate from expected patterns. Adequate customer due diligence is a foundational requirement of the Bank Secrecy Act framework and a standard expectation applied by the OCC across all federally chartered institutions.

The bank is also required to implement ongoing transaction monitoring, a systematic process through which customer activity is continuously reviewed against established behaviour profiles and escalated for investigation when anomalies are detected. Effective transaction monitoring is widely regarded as a cornerstone of AML compliance and is a primary area of focus during OCC examinations of BSA programme adequacy. The formal agreement requires these improvements to be documented, tested, and embedded into the bank's day-to-day operations.

REPORTING OBLIGATIONS AND BROADER CONTEXT

Consistent with standard OCC enforcement practice, First National Bank & Trust must submit periodic written progress reports to the regulator outlining the steps it has taken to fulfil each requirement of the formal agreement. The reporting mechanism allows the OCC to monitor remediation milestones on a structured schedule and to assess whether the bank is making satisfactory progress within the agreed timeframes. A failure to meet the required remediation benchmarks could prompt the regulator to consider escalation to more stringent enforcement measures.

Community banks of First National Bank & Trust's size have faced heightened BSA/AML expectations in recent years as the OCC and other federal regulators have extended the compliance standards traditionally associated with larger institutions across the entire regulated population. The agency has made clear that all nationally chartered banks, regardless of asset scale or geographic footprint, are expected to operate risk-based BSA/AML programmes commensurate with the complexity of their customer relationships and the volume and types of transactions they process.