OCC enforcements include $3 million in fines over FX spot trade practices, $1.675 million in fines for former Wells managers

Seventeen enforcement orders spanning the months of August to October – including civil money penalties in the hundreds of thousands and millions of dollars – were released Thursday by the Office of the Comptroller of the Currency (OCC).

Foreign exchange trading is featured in two of the orders. Those orders, which are amended orders, impose $1.5 million civil money penalties on both Richard Usher and Rohan Ramchandani, former spot traders for JPMorgan Chase Bank, N.A. (Columbus, Ohio) and Citibank, N.A. (Sioux Falls, S.D.), respectively. The two reportedly breached their fiduciary duties by agreeing with traders at competitor banks to coordinate trading in the foreign exchange spot market. The OCC seeks to prohibit both individuals from any future involvement in any federally insured financial institution.

Wells Fargo Bank, N.A. (Sioux Falls, S.D.) is also featured in the current list, which shows three orders against former bank managers for their roles during the bank’s long-running “systemic sales practices misconduct problem”:

  • Matthew Raphaelson, former group finance officer and head of finance/strategic planning, assessed a $925,000 civil money penalty and prohibited from future service in any federally insured financial institution;
  • Tracy Kidd, former head of community bank human resources, ordered to cease and desist and to pay a $350,000 civil money penalty; and
  • Kenneth Zimmerman, former head of the deposit products group, ordered to cease and desist and assessed a $400,000 penalty.

Thursday’s release by the OCC also notes orders previously reported here, including the $85 million penalty against USAA Federal Savings Bank over alleged violations of military servicemember protection statutes; and $400 million fine against Citibank over risk management and internal controls deficiencies.

Among the remaining orders were an $82,500 penalty against CIT Bank, National Association (Pasadena, Calif.), related to findings of federal flood insurance violations; and a notice on a $60 million fine against Morgan Stanley Bank, N.A. (Salt Lake City, Utah) related to findings of unsafe or unsound practices relating to information security and noncompliance.

OCC Enforcement Actions and Terminations

RR: USAA assessed $85 million penalty for violations of servicemember protection laws (Oct. 14, 2020)

RR: $400 million penalty forced on Citibank after ‘long-standing’ failure to correct compliance shortcomings (Oct. 7, 2020)

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