The Office of the Comptroller of the Currency (OCC) has published an AML sanctions consent order for Wells Fargo, highlighting substantial compliance challenges that remain. The comprehensive 28-page order outlines several critical areas requiring attention, including enhancing risk management practices at both the front and second lines, strengthening audit functions with rigorous “audit test scripts,” and performing thorough risk assessments across all business units. Additionally, Wells Fargo must evaluate and upgrade its data systems and establish a robust Data Integrity Program, given the complexity of its operations. Managing these changes and integrating new business ventures will be a formidable task, emphasizing that strict adherence to AML and sanctions compliance standards is essential for any financial institution, regardless of its size.
Read the consent order here: Cease and Desist Order 2015-048 (occ.gov)