The Office of the Comptroller of the Currency (OCC) today released enforcement actions taken against national banks and federal savings associations (banks), and individuals currently and formerly affiliated with banks the OCC supervises.
The OCC uses enforcement actions against banks to require the board of directors and management to take timely actions to correct the deficient practices or violations identified. Actions taken against banks are:
- Formal Agreement with Carver Federal Savings Bank, New York, New York, for unsafe or unsound practices, including those related to strategic planning and earnings performance. (Docket No. AA-NE-2025-18)
- Formal Agreement with Sterling Federal Bank, FSB, Sterling, Illinois, for unsafe or unsound practices, including those related to strategic planning, capital planning, credit administration, and liquidity risk management. (Docket No. AA-CE-2025-22)
- Formal Agreement with Texas Heritage National Bank, Daingerfield, Texas, for unsafe or unsound practices, including those related to strategic planning, capital planning, liquidity risk management, interest rate risk management, concentration risk management, the allowance for credit losses, and violations of law, rule, or regulation, including those relating to reports of condition and independent audit. (Docket No. AA-SO-2025-32)
The OCC uses enforcement actions against an institution-affiliated party (IAP) to deter, encourage correction of, or prevent violations, unsafe or unsound practices, or breaches of fiduciary duty. Enforcement actions against IAPs reinforce the accountability of individuals for their conduct regarding the affairs of a bank. The term “institution-affiliated party,” or IAP, is defined in 12 USC 1813(u) and includes bank directors, officers, employees, and controlling shareholders. Orders of Prohibition prohibit an individual from any participation in the affairs of a bank or other institution as defined in 12 USC 1818(e)(7). Actions taken against IAPs are:
- Order of Prohibition against William Shane Garrow, former Private Banker at BOKF, N.A., Tulsa, Oklahoma, for misappropriating over $3 million from bank customers’ accounts for his personal benefit. (Docket No. AA-SO-2025-28)
- Order of Prohibition against Amilcar A. Sanchez, former Branch Operations Manager and ATM Custodian at a Long Island City, New York, branch of Santander Bank, N.A., Wilmington, Delaware, for stealing, embezzling, or otherwise misappropriating $370,000 from the bank. (Docket No. AA-ENF-2025-17)
The OCC terminates enforcement actions when a bank has demonstrated compliance with all articles of an enforcement action; or when the OCC determines that articles deemed “not in compliance” have become outdated or irrelevant to the bank’s current circumstances; or when the OCC incorporates the articles deemed “not in compliance” into a new action. Termination actions include:
- Order Terminating two Graham-Leach-Bliley Act Agreements with Wells Fargo Bank, N.A., Sioux Falls, South Dakota, both dated September 15, 2015 (#2015-105 and #2015-106). The two GLBA Agreements related to the bank’s non-compliance with certain requirements for controlling or holding an interest in financial subsidiaries. (Docket No. AA-ENF-2025-35)
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All OCC public enforcement actions taken since August 1989 are available for download by viewing the searchable enforcement actions database at https://apps.occ.gov/EASearch.
