The Office of the Comptroller of the Currency announced on 20 February 2025 a formal agreement, dated 14 January 2025, with Patriot Bank, N.A., headquartered in Stamford, Connecticut, following identified violations and unsafe or unsound practices in the bank's operations. The enforcement action covers violations and unsafe or unsound practices relating to strategic planning, capital planning, Bank Secrecy Act and anti-money laundering risk management, payment activities oversight, credit administration and concentration risk management.
CAPITAL FLOOR AND BSA/AML ACTION PLAN REQUIRED
Under the terms of the agreement, Patriot Bank is required to achieve and maintain a Common Equity Tier 1 capital ratio of at least 10%. The bank must also submit a written strategic plan to the OCC and submit a BSA action plan together with separate programmes covering customer identification for reloadable prepaid card accounts, suspicious activity monitoring and reporting, the BSA/AML risks of prepaid card products offered through third-party program managers, and a payment activities oversight programme.
COMPLIANCE COMMITTEE AND QUARTERLY REPORTING MANDATED
The OCC also required Patriot Bank to establish a compliance committee of at least three members by 31 January 2025. The committee, which must have a majority of directors who are not employees of the bank, is charged with monitoring and overseeing the bank's adherence to the agreement and submitting written progress reports to the bank's board within 30 days after the end of each quarter.
The formal agreement with Patriot Bank was announced alongside a separate formal agreement with Dearborn Federal Savings Bank in Michigan, as part of the OCC's February 2025 enforcement release, which also included six orders of prohibition against individuals.