Bank Enforcement Actions by Type: OCC and Federal Reserve (2016 to 2025)

57% of the enforcement orders the OCC and the Federal Reserve issued from 2016 to 2025 were against individuals, not institutions, according to both agencies' records. That is 586 of 1,028 OCC and Federal Reserve orders. Against individuals the most common order is a prohibition, removal or suspension, 396 of them; against institutions it is a civil money penalty, 170 of 442, ahead of a cease-and-desist or consent order at 135, according to the same records.

Every count is from the OCC's Enforcement Actions Search and the Federal Reserve Board's enforcement actions file, through October 13, 2026. The FDIC is not included: it publishes its enforcement orders through a search application rather than as a file, and they are not counted here.

Enforcement orders by type, 2016 to 2025

Each agency's own label, grouped into the kinds both use. An action that combines two kinds, such as a cease-and-desist order with a penalty, counts under each.

Type of order	OCC, institutions	OCC, individuals	Federal Reserve, institutions	Federal Reserve, individuals	Total	Source
Prohibition, removal or suspension	0	280	0	116	396	Data from the OCC, Federal Reserve
Civil money penalty	78	152	92	11	333	Data from the OCC, Federal Reserve
Cease-and-desist or consent order	77	84	58	16	235	Data from the OCC, Federal Reserve
Formal or written agreement	88	0	43	0	131	Data from the OCC, Federal Reserve
Prompt corrective action or capital directive	7	0	3	0	10	Data from the OCC, Federal Reserve
Other (notices of charges, amendments, other orders)	4	39	1	17	61	Data from the OCC, Federal Reserve

Enforcement orders by year

Year	OCC	Federal Reserve	Against institutions	Against individuals	Source
2016	89	33	57	65	Data from the OCC, Federal Reserve
2017	80	45	62	63	Data from the OCC, Federal Reserve
2018	81	48	53	76	Data from the OCC, Federal Reserve
2019	63	36	38	61	Data from the OCC, Federal Reserve
2020	79	30	47	62	Data from the OCC, Federal Reserve
2021	45	33	38	40	Data from the OCC, Federal Reserve
2022	50	33	23	60	Data from the OCC, Federal Reserve
2023	54	22	39	37	Data from the OCC, Federal Reserve
2024	100	37	70	67	Data from the OCC, Federal Reserve
2025	47	23	15	55	Data from the OCC, Federal Reserve
2026 (through October 13, 2026)	18	35	13	40	Data from the OCC, Federal Reserve

What the OCC names in its orders against banks

The OCC records the subjects each order addresses, for actions from 2012 on. An order can name several, so the shares add to more than the whole. According to the OCC, Strategic Planning appears in 95 of its 252 orders against institutions from 2016 to 2025, and Board / Management Oversight in 92. The Federal Reserve's file records no subjects.

Subject the OCC names	OCC orders against institutions	Share	Source
Strategic Planning	95	38%	Data from the OCC
Board / Management Oversight	92	37%	Data from the OCC
Lending Issues	84	33%	Data from the OCC
BSA/AML	78	31%	Data from the OCC
Capital	77	31%	Data from the OCC
Consumer Law	68	27%	Data from the OCC
Liquidity	58	23%	Data from the OCC
Audit	56	22%	Data from the OCC
Enterprise Governance / Internal Controls / General Risk Management	54	21%	Data from the OCC
Asset Quality	43	17%	Data from the OCC

The 20 largest civil money penalties

All years in either agency's record, largest first. Where an OCC order assesses one penalty against several banks, it is counted once.

Rank	Date	Agency	Party	Civil money penalty	Source
1	October 13, 2026	OCC	Bank of America, National Association	$750 million	Data from the OCC
2	June 30, 2014	Federal Reserve	BNP Paribas, S.A., Paris, France	$508 million	Federal Reserve
3	December 11, 2012	OCC	HSBC Bank USA, National Association	$500 million	Data from the OCC
4	April 20, 2018	OCC	Wells Fargo Bank, National Association	$500 million	Data from the OCC
5	October 9, 2024	OCC	TD Bank USA, National Association, with 1 other bank in the same order	$450 million	Data from the OCC
6	October 7, 2020	OCC	Citibank, National Association	$400 million	Data from the OCC
7	October 8, 2026	OCC	American Express National Bank	$350 million	Data from the OCC
8	January 7, 2014	OCC	Chase Bank USA, National Association, with 2 other banks in the same order	$350 million	Data from the OCC
9	November 11, 2014	OCC	Citibank, National Association	$350 million	Data from the OCC
10	November 11, 2014	OCC	JPMorgan Chase Bank, National Association	$350 million	Data from the OCC
11	May 20, 2015	Federal Reserve	JPMORGAN CHASE & CO. New York, New York	$342 million	Federal Reserve
12	May 20, 2015	Federal Reserve	Citigroup, Inc., New York, New York	$342 million	Federal Reserve
13	May 20, 2015	Federal Reserve	BARCLAYS BANK PLC London, England	$342 million	Federal Reserve
14	May 20, 2015	Federal Reserve	UBS AG Zurich, Switzerland	$342 million	Federal Reserve
15	September 18, 2013	OCC	JPMorgan Chase Bank, National Association	$300 million	Data from the OCC
16	February 9, 2012	Federal Reserve	JPMorgan Chase & Co., New York, New York and EMC Mortgage Corporation, Lewisville, Texas	$275 million	Federal Reserve
17	May 20, 2015	Federal Reserve	THE ROYAL BANK OF SCOTLAND PLC, Edinburgh, Scotland	$274 million	Federal Reserve
18	July 21, 2023	Federal Reserve	UBS Group AG, Zurich, Switzerland, Credit Suisse AG, Zurich, Switzerland, Credit Suisse Holdings (USA), Inc., New York, New York, Credit Suisse AG, New York Branch, New York, New York	$269 million	Federal Reserve
19	November 11, 2014	OCC	Bank of America, National Association	$250 million	Data from the OCC
20	March 14, 2024	OCC	JPMorgan Chase Bank, National Association	$250 million	Data from the OCC

Download this table (CSV), free. The full dataset, every OCC and Federal Reserve action with its type, party, penalty and document, is one email away.

What the orders are

The OCC describes its formal actions this way. A cease-and-desist order requires a bank or an individual to stop an unsafe or unsound practice or violation and to correct what it caused; a restitution order is a kind of cease-and-desist order. A formal agreement is a written agreement signed by the OCC and a bank's board. A prohibition order bars an individual from taking part in the affairs of any insured depository institution. A civil money penalty order requires a bank or an individual to pay a penalty. The Federal Reserve uses the same kinds, and calls its agreements written agreements.

Some listings are not orders. A Federal Reserve Section 19 letter or an OCC 1829 notification tells a person that the law itself bars them after a conviction for certain crimes. The OCC's search leaves out such notifications dated before December 23, 2022, as its search page states. They are counted apart here, 338 from 2016 to 2025 (271 from the Federal Reserve and 67 from the OCC, according to their records), and left out of every share above.

What this means for technology buyers

The subjects the OCC names most often in its orders against banks are strategic planning, board and management oversight, lending issues, BSA/AML and capital. These guides compare systems for the audit, compliance and reporting work those subjects involve:

• Audit management systems for financial services: planning audits and tracking findings to closure, including the actions an order requires.
• AML transaction monitoring for banks and fintechs: the Bank Secrecy Act controls the OCC's orders name among their subjects.
• Regulatory reporting platforms for Basel compliance: capital and liquidity reporting.
• Predictive analytics platforms for credit risk: credit risk models, for the lending and asset quality subjects.

Mapping what a bank runs before choosing the systems? The Retail Bank Business Capability Model places compliance, audit and risk among the bank's other capabilities.

More from Finantrix Atlas

• Bank Secrecy Act enforcement: FinCEN actions and penalties
• CFPB enforcement actions
• OFAC sanctions penalties
• US bank failures

How this was built

The universe is every action in the OCC's Enforcement Actions Search, 6,071 records, and every row of the Federal Reserve Board's enforcement actions file, 2,898 rows, read on the date of the data. The OCC's records were reconciled against the OCC's own count service in total, by institution and individual, and for every year. The Federal Reserve's file was reconciled row by row against the data its search page reads.

The OCC's record lists each kind of order separately, so records for the same party, document and date are combined into one action, as the Federal Reserve's file lists them. The window is the 10 full years before the current one. Institution or individual is each agency's own classification; the OCC counts every institution-affiliated party as an individual, which can include a company that served a bank.

The OCC's record states each penalty. The Federal Reserve's file states most penalties in its description of the action; for the 37 where it does not and the press release or order does, the amount was read from the sentence that states it, and that sentence is in the dataset. 49 penalty actions in the OCC and Federal Reserve records carry no amount here.

Limits

• Two of the three federal banking agencies. The FDIC's orders are not counted, nor are the CFPB's, the states' or the Justice Department's.
• A count is not a measure of severity. A formal agreement with a small bank and a penalty against a global bank each count once.
• Combined orders count under each kind. The type table therefore adds to more than the number of orders.
• Statutory bars are counted apart, because the OCC lists only those from December 23, 2022 on.
• Penalties as assessed. A penalty can be satisfied in part by payments to another agency, and some penalty actions carry no published amount.
• Names as published, as each party stood when the action was taken. The data runs through October 13, 2026.

Cite this

Free to quote, cite and republish, including the chart, with credit to Finantrix Atlas and a link to this page.

57% of OCC and Federal Reserve enforcement orders from 2016 to 2025 were against individuals rather than institutions, according to a Finantrix Atlas analysis of both agencies' enforcement records.

Suggested citation: Finantrix Atlas, "Bank Enforcement Actions by Type: OCC and Federal Reserve," through October 13, 2026, from OCC and Federal Reserve enforcement records. https://www.finantrix.com/articles/bank-enforcement-actions

Embed the chart:

<a href="https://www.finantrix.com/articles/bank-enforcement-actions"><img src="https://www.finantrix.com/atlas/bank-enforcement-actions.png" alt="OCC and Federal Reserve enforcement orders by type, from Finantrix Atlas"></a>
<p>Chart: <a href="https://www.finantrix.com/articles/bank-enforcement-actions">Finantrix Atlas</a>, from OCC and Federal Reserve enforcement records.</p>

Frequently asked questions

Q: What enforcement actions do bank regulators take most often? A: From 2016 to 2025, the most common OCC and Federal Reserve order was a prohibition, removal or suspension, 396 of 1,028, according to both agencies' records.

Q: Do bank regulators take action against individuals? A: Yes. 57% of OCC and Federal Reserve orders from 2016 to 2025 were against individuals, most often a prohibition, removal or suspension, according to the agencies' records.

Q: What is the largest civil money penalty the OCC or the Federal Reserve has assessed? A: Bank of America, National Association, $750 million, assessed by the OCC in 2026, according to the agency's record.

Q: Does this include the FDIC? A: No. The FDIC publishes its enforcement orders through a search application rather than as a file, so its orders are not counted here.