OCC Announces Enforcement Actions for September 2025

WASHINGTON-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.

• The OCC does not have any enforcement actions against banks to release in September.

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). The OCC has taken the following actions against IAPs:

• Order of Prohibition against Armando De Leon, former Store Manager at a Hialeah, Florida, branch of TD Bank, N.A., Wilmington, Delaware, based on the OCC's uncontested allegations in the Notice of Charges that, among other things, De Leon submitted fraudulent Payment Protection Program (PPP) loan applications, received over $80,000 in PPP loan proceeds, and used the funds for personal gain. (Docket No. AA-ENF-2024-35)
• Order of Prohibition against Carolyn H. Hicks, former Bank Operations Assistant Manager at a Columbus, Georgia, branch of Wells Fargo Bank, N.A., Sioux Falls, South Dakota, for misappropriating approximately $25,000 from a bank ATM. (Docket No. AA-ENF-2025-43)
• Order of Prohibition against Charron Meadows, former Team Manager at a Mount Laurel, New Jersey, call center of TD Bank, N.A., Wilmington, Delaware, for misappropriating at least $150,000 from the bank. (Docket No. AA-ENF-2025-41)
• Order of Prohibition against Gerald E. Milligan II, former Teller at a Royal Palm, Florida, branch of PNC Bank, N.A., Wilmington, Delaware, based on the OCC's uncontested allegations in the Notice of Charges that, among other things, Milligan knowingly made false attestations and provided false supporting documentation for a PPP loan application, received PPP loan proceeds in the amount of $141,530, and used the funds for personal gain. (Docket No. AA-EC-2024-12)
• Order of Prohibition against Walther Riano-Vanegas, former Teller at a Linden, New Jersey, branch of Wells Fargo Bank, N.A., Sioux Falls, South Dakota, for stealing $15,670 from two ATMs at the branch. (Docket No. AA-ENF-2025-40)

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 the Cease and Desist Order against Gateway Bank, F.S.B., Oakland, California, dated November 12, 2020 (Docket No. AA-ENF-2020-69). The terminated order addressed unsafe or unsound practices, including those related to board and management supervision, internal audit, credit administration, and consumer compliance management, and for unsafe or unsound practices and violations of law related to the bank's Bank Secrecy Act/anti-money laundering compliance program. (Docket No. AA-ENF-2025-47)
• Order Terminating the Cease and Desist Order against Vast Bank, N.A., Tulsa, Oklahoma, dated October 23, 2023 (Docket No. AA-SO-2023-44). The terminated order addressed unsafe or unsound practices, including those related to capital, capital and strategic planning, project management, books and records, liquidity risk management, interest rate risk management, information technology controls, risk management for new products, and custody account controls. (Docket No. AA-SO-2025-49)

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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.

Related Link

• Enforcement Action Types