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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. Actions taken against banks are:

• Formal Agreement with Comerica Bank & Trust, National Association, Ann Arbor, Michigan, for unsafe or unsound practices, including those relating to the bank’s risk governance framework and internal controls. (Docket No. AA-NE-2024-39)
• Formal Agreement with Lemont National Bank, Lemont, Illinois, for unsafe or unsound practices, including those relating to capital planning, strategic planning, succession planning, and liquidity risk management. (Docket No. AA-CE-2024-38)

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 Stanley Acosta, former Senior Specialist Relationship Banker, at a Dartmouth, Massachusetts, branch of Santander Bank, N.A., Wilmington, Delaware, for stealing approximately $27,449 from cash deposit bags that customers provided to the bank via the night deposit vault. (Docket No. AA-ENF-2024-37)
• Order of Prohibition against Bahtia Greene, former Associate Operations Processor, at the Philadelphia, Pennsylvania, lockbox facility for Wells Fargo Bank, N.A., Sioux Falls, South Dakota, for misappropriating confidential information of bank customers and selling the information to a third party, resulting in fraudulent transactions and a loss to the bank of approximately $688,000. (Docket No. AA-ENF-2024-28)
• Notice of Charges for Gerald E. Milligan, II, former Teller, at a Royal Palm, Florida, branch of PNC Bank, N.A., Wilmington, Delaware. The Notice of Charges alleges, among other things, that Milligan knowingly made false attestations and provided false supporting documentation for a Paycheck Protection Plan (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 Sabina Prince, former Teller at a Mountain Brook, Alabama, branch of PNC Bank, National Association, Wilmington, Delaware, for taking $15,000 in cash from the bank and manipulating cash shipment processing receipts to hide her actions. (Docket No. AA-ENF-2024-16)
• Order of Prohibition against Stephanie Sanders, former Relationship Banker, at NBT Bank, N.A., Norwich, New York, for misappropriating approximately $30,650 from the bank by crediting her checking and savings accounts over 100 times. (Docket No. AA-ENF-2023-35)

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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.

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