Audit Report

OIG-17-006

SAFETY AND SOUNDNESS:

OCC’s Fast Track Enforcement Program Should Be Assessed

November 14, 2016

Office of

Inspector General

Department of the Treasury
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Contents

OCC’s Fast Track Enforcement Program Should Be Assessed

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Page i

Audit Report

Results in Brief.............................................................................................. 2

Background .................................................................................................. 3

Audit Results ................................................................................................ 8

OCC Should Assess Fast Track ...................................................................9

Recommendation..........................................................................................14

Appendices

Appendix 1: U.S. Attorney's Office, District of Minnesota News Release....... 16 

Appendix 2: OCC Examination Procedures Relating to Criminal Activities ...... 22 

Appendix 3: Objectives, Scope, and Methodology ...................................... 25 

Appendix 4: Management Response ......................................................... 29 

Appendix 5: Major Contributors to This Report........................................... 31 

Appendix 6: Report Distribution................................................................ 32 

Abbreviations

BSA Bank Secrecy Act

E&C Enforcement and Compliance

FBO foreign banking organizations

FinCEN Financial Crimes Enforcement Network

Fast Track Fast Track Enforcement Program

GPRMA Government Performance and Results Modernization Act of 2010

IAP Institution-Affiliated Party

OCC Office of the Comptroller of the Currency

OTS Office of Thrift Supervision

PACER Public Access to Court Electronic Records

 PPM Policies and Procedures Manual

SAR Suspicious Activity Report

USAO United States Attorney’s Office
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OIG Audit

Report

The Department of the Treasury

Office of Inspector General

OCC’s Fast Track Enforcement Program Should Be Assessed Page 1 

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Audit Report

November 14, 2016 

Thomas J. Curry

Comptroller of the Currency

Office of the Comptroller of the Currency

This report presents the results of our audit of the Office of the 

Comptroller of the Currency’s (OCC) supervision of bank processes 

to prevent, detect, and report criminal activities by insiders. We 

performed this audit out of concern over a case brought to our 

attention by the U.S. Attorney’s Office (USAO), District of 

Minnesota. The case was discussed in a 2012 news release in 

which USAO announced that a California man and a New York man 

were sentenced in federal court in Minneapolis for their roles in a 

$50-million bank fraud conspiracy that operated in six states, 

involved a network of bank employees, and victimized more than 

500 individuals around the world by stealing their personal and 

financial information.

1 Appendix 1 provides more details of this 

case.

The objectives of our audit were to specifically: (1) identify the 

extent and nature of criminal and other suspicious activity 

committed by bank insiders reported to Financial Crimes 

Enforcement Network (FinCEN) under the Bank Secrecy Act (BSA) 

through a review of Suspicious Activity Reports (SARs) and related 

analytical studies; (2) identify OCC processes for pursuing 

enforcement actions against current or former bank insiders for

which there is evidence of wrongdoing involving dishonesty, a 

breach of trust, or money laundering; (3) identify OCC examination 

procedures to ensure banks have sufficient processes to prevent, 

detect, and report internal criminal activities; (4) determine whether 

the procedures are applied; and (5) determine whether deficiencies 

identified during the examination process result in supervisory 

actions that are tracked. 

 

1

 This case resulted from an on-going investigation, referred to as Operation Starburst. The 

investigation was led by the Minnesota Financial Crimes Task Force. The Office of Inspector General’s 

Office of Investigations participated on the task force.
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To accomplish our objectives, we reviewed applicable laws,

regulations, policies, procedures, and guidance, as well as related 

documentation obtained from OCC or FinCEN. We interviewed key 

OCC officials and staff headquartered in Washington, D.C. and 

field offices in Wichita, Kansas; San Francisco, California; 

Minneapolis, Minnesota; and Birmingham, Alabama. We also 

interviewed key FinCEN officials in Washington, D.C. The scope of 

our audit ranged from calendar years 2009 through 2011. We 

conducted our fieldwork between December 2011 and June 

2016.

2 Appendix 3 contains a detailed description of our 

objectives, scope, and methodology.

Results in Brief

OCC faces a considerable task in confronting bank insider

wrongdoing. The volume of SARs received by FinCEN suggests 

that suspicious activity by bank insiders is still a large problem. 

During 2009–2011, FinCEN received and OCC downloaded into its 

SAR Fast Track Enforcement Program (Fast Track) database

approximately 2.2 million SARs from banks, of which,

approximately 1.3 million were filed by banks regulated by OCC or 

the legacy Office of Thrift Supervision (OTS), 48,500 of which 

involved bank insiders.

3

We found OCC’s examination procedures reasonably address the 

prevention and detection of criminal activities by bank insiders if 

performed as warranted during ongoing safety and soundness 

examinations. Furthermore, OCC’s procedures include tracking of

supervisory actions for any deficiencies identified during the 

examinations.

OCC’s Fast Track, administered by the Chief Counsel Office’s

Enforcement and Compliance (E&C) Division, implements 

“streamlined enforcement” procedures aimed at keeping the 

banking industry safe and sound by using information from SARs, 

examinations, alerts, or other sources to pursue prohibitions of 

 

2 Given the time that has elapsed since initiating this audit, we continuously followed-up with OCC to 

ensure the information supporting our audit did not change. 3 OCC assumed supervisory responsibilities for savings and loans associations in July 2011 from the 

legacy OTS pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act.
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bank insiders from working in a financial institution, when bank 

insiders and other Institution-Affiliated Parties (IAPs) commit 

criminal acts or acts of significant wrongdoing involving banks.

Under the authority of 12 U.S.C. 1818 (1818) or 12 U.S.C. 1829

(1829), OCC pursues enforcement actions against current or 

former bank employees for which there is evidence of wrongdoing, 

dishonesty, a breach of trust, or money laundering. We found that 

the policies and procedures for Fast Track were consistently 

followed. However, Fast Track was not as efficient and effective in 

pursuing prohibitions as it could be. The last assessment of Fast 

Track was completed in 2009 and did not include the 

establishment of specific performance metrics or an analysis of 

staffing levels needed to meet program goals. We concluded that 

Fast Track’s staffing model limited the number of cases Fast Track

could process.

Accordingly, we recommend that OCC assess Fast Track to 

determine whether the program’s efficiency and effectiveness 

could be increased. This assessment should include, but is not 

limited to, the program’s mission and goals, comprehensive 

requirements, performance results over time, current staffing 

levels, and additional training needs. As part of our reporting 

process, we provided a draft of this report to OCC management to 

obtain their views and comments. After incorporating comments as 

appropriate, OCC management provided a written response in 

which it agreed with our recommendation. Management further 

stated that OCC will assess the Fast Track Program to determine 

whether it is feasible to improve the program’s efficiency and 

effectiveness to include processing more 1818 prohibition cases. 

We found OCC management’s response meets the intent of our 

recommendation and have summarized the response in the 

recommendation section of this report. The response is provided it 

in its entirety as Appendix 4.

Background

Internal fraud and unethical conduct within banks is of particular 

concern because of the position that banks hold in the financial 

system. Bank insiders have significant opportunity to benefit 

personally from unethical behavior. They have access to and 

control over large quantities of liquid financial assets, non-public 
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personal information, and business information. Individual instances

of internal bank fraud can be significant for the banks and 

individual victims. According to fraud analysts, many banks are 

unwilling to report internal thefts to authorities. Banks often make 

the decision whether to prosecute cases based on sufficient proof

and the risk to their reputation associated with having it publicly 

known. This may result in many banks firing the insiders without 

pursuing prosecution, which gives rise to the potential of an 

unethical bank insider perpetuating internal bank fraud should the 

individual seek employment with a different bank. 

Responsibilities of Banks Relating to the Prevention, Detention, and 

Reporting of Internal Criminal Activities

Banks play a key role in preventing, detecting, and reporting 

internal criminal activities, and are primarily responsible for using 

due diligence when: (1) hiring employees; (2) reporting suspicious 

activity and potential fraud of bank insiders; (3) establishing and 

maintaining effective internal controls to identify and control risks; 

(4) incorporating internal or external audit systems appropriate to 

the size and nature of the activities of the bank; and (5) developing 

and implementing safeguards to protect the security, 

confidentiality, and integrity of consumer information.

Responsibilities of FinCEN

FinCEN is responsible for ensuring the collection, analysis, and 

dissemination of information collected under BSA, including, most 

notably, SARs. These reports serve not only to provide law 

enforcement, intelligence, and regulatory agencies with leads 

indicative of illicit activity, but also to provide a fertile source for 

identifying trends and patterns of illicit activity, as well as 

compliance-related deficiencies.

Responsibilities of OCC

OCC’s Fast Track:

Fast Track is primarily a law department-supported program, with 

leadership and coordination of the program housed within the E&C 

Division. Fast Track was established in 1995 to implement OCC’s 

policy to support and enforce the requirements of banks to report 
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violations of federal criminal law to FinCEN, as well as applicable 

enforcement statutes, aimed at keeping the banking industry safe 

and sound. Fast Track has a Policy and Procedures Manual (PPM)

5310-8 4 that includes guidelines to support and enforce the 

requirements of applicable enforcement statutes. It also has a 

program procedures manual5 detailing procedures for pursuing 

prohibitions under the authority of these statutes.

According to the program procedures manual, the program takes 

enforcement actions to prohibit current or former bank insiders

from working at banks. BSA requires banks to report criminal 

violations or other suspicious transactions related to money 

laundering activity or BSA by filing a SAR with FinCEN. The SAR 

details the facts about the activity that may serve as the basis for 

criminal investigation and prosecution by law enforcement 

agencies. Under the authority of 1818 or 1829, Fast Track uses

information from SARs, examinations, alerts, or other sources to 

pursue enforcement actions against current or former bank insiders 

to prohibit them from working in an insured depository institution if 

there is sufficient evidence of wrongdoing, dishonesty, a breach of 

trust, or money laundering.

The information is screened and selected for case processing based

primarily on the following criteria, amongst others: (1) the 

wrongdoing involves the following identifiers: director, officer, 

employee, agent & owner (or controlling agent) (with priority given 

to officers, directors and other identifiers who are the subject of 

multiple SARs); (2) the amount involved is at least $5,0006 (with

priority given to cases involving $25,000 or more); and (3) the date 

of the SAR filing is within the preceding two years. OCC may also 

focus on cases in a special area of interest such as identity theft, 

privacy of customer records, or mortgage fraud.

OCC’s E&C Division has primary responsibility for the program and 

for determining whether to pursue prohibition actions under 1818 

and 1829, as follows:

 

4 OCC’s PPM 5310-8 (REV), Fast Track Enforcement Program (December 20, 2007). 5 OCC’s Fast Track Enforcement Program Procedures Manual (June 19, 2012). 6 This standard is satisfied if more than one SAR is filed on an IAP and the aggregated amount 

involved is at least $5,000.
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1818: OCC can pursue an 1818 prohibition order, which is an 

industry-wide ban on an employee from working in an insured 

depository institution. The ban remains in effect indefinitely 

unless terminated by OCC. Under Fast Track, OCC pursues an

1818 prohibition order when there is an admission of 

wrongdoing, or OCC has obtained clear evidence of

wrongdoing, and the amount of the loss or transaction is at 

least $5,000.

More specifically, OCC is required to establish that: (1) the 

employee violated the law, regulation, cease and desist order, 

formal agreement, or condition imposed in writing, participated 

in an unsafe or unsound banking practice or committed a 

breach of fiduciary duty; (2) such conduct resulted or will 

probably result in a loss to the bank, resulted in financial gain 

or other benefit to the employee, or has prejudiced the interests 

of the depositors; and (3) such conduct evidences dishonesty 

or a continuing or willful disregard for the safety and soundness 

of the bank. 1818 prohibition orders are obtained by consent of 

the employee or by the issuance of a final order of the 

Comptroller following a hearing before an administrative law 

judge.

7

1829: Under 1829, an individual is effectively prohibited by 

operation of law from working in an insured depository 

institution once he or she has been convicted of, or upon 

entering into a pretrial diversion program for,

8 a crime involving 

dishonesty or breach of trust. In such cases, OCC obtains the 

judgment or conviction documents from the court and sends 

the individual an 1829 prohibition letter informing him or her of 

the automatic prohibition. If, after receiving such a letter, the 

person re-enters the banking industry in violation of 1829, he 

or she does so knowingly and may, therefore, be subject to 

criminal fines and penalties. The ban remains in effect 

 

7 A prohibition order issued by the Comptroller may be appealed into federal circuit court. 8 Types of pretrial diversion programs are deferred prosecution, deferred sentencing, or deferred 

adjudication that avoids conviction if the person successfully completes a probationary period. Under 

a typical federal pretrial diversion agreement, an offender enters into a program of supervised 

probation, and upon successful completion, the U.S. Attorney will decline prosecution, and the 

charges will be dismissed. Similar programs at the state level have various names, including deferred 

prosecution agreements. They will be referred to hereafter, collectively, as pretrial diversion 

programs.
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indefinitely, unless terminated by the Federal Deposit Insurance 

Corporation.

OCC may close a case when: (1) there is no admission and no clear 

evidence of wrongdoing; (2) several unsuccessful attempts have 

been made to contact the individual; or (3) the 5-year statute of 

limitations has run.9 In such cases, a no-action memo is written. 

Final decisions on no-action cases will be made by the E&C

Division, which will determine, for example: (1) whether a case 

should be pursued even when the initial evidence is not clear, if

such cases may be developed through further investigation, 

including (in rare cases) an order of investigation; or (2) in cases 

where the 5-year statute of limitations has run, whether an 

enforcement action short of a prohibition should be pursued (such 

as a personal cease and desist order) after taking into account 

litigation risks.

As required by 1818, OCC lists the names of the recipients of

1818 prohibition orders on its website. OCC also lists the names of 

the recipients of 1829 prohibition letters on its website. Through 

this means, OCC is able to inform the public, including banks 

making employment decisions, that certain individuals are 

prohibited from working in the banking industry. These 

enforcement actions taken by OCC are searchable through an 

Enforcement Action Search Tool on the website.

OCC Safety and Soundness Examinations:

OCC performs safety and soundness examinations of banks on an 

ongoing basis. For supervisory purposes, OCC designates each 

bank as large, mid-size, or community bank. Large and mid-size 

banks are supervised through the OCC headquarters office, which 

follows a supervisory process detailed in its Bank Supervision 

booklet. Examinations are performed on a 12-month supervisory 

 

9 1818 prohibition orders are subject to a 5-year statute of limitations. In general, to avoid statute of

limitations issues, OCC has 5 years from the date of the bank insider’s bad act to settle the case or 

file a notice of charges. A case may also be closed if the subject of the SAR is a foreign national who 

has committed a criminal act or significant wrongdoing in a foreign country where no domestic 

accounts were involved.
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cycle. Community banks and federal branches of foreign banks10

are supervised under the oversight of district deputy comptrollers,

which follow a supervisory process detailed in the “Community 

Bank Supervision” booklet and the “Federal Branches and Agencies 

Supervision” handbook. In smaller national bank affiliates, 

community banks, and federal branches and agencies of foreign 

banks, there is flexibility in both when and how examination 

activities are performed during the 12 or 18-month supervisory 

cycle. OCC employs a risk-based supervisory philosophy focused 

on evaluating risk, identifying problems, and ensuring banks take 

appropriate corrective action.

Audit Results

OCC faces a considerable task in confronting bank insider

wrongdoing. We found that the volume of SARs received by 

FinCEN suggests that suspicious activity by bank insiders is a large 

problem. During 2009–2011, FinCEN received, and OCC 

downloaded into its SAR Fast Track database, approximately 

2.2 million SARs from banks, of which, approximately 1.3 million 

were filed by banks regulated by OCC or the legacy OTS. 

Furthermore, of the 1.3 million SARs, there were approximately 

48,500 IAP11 relationships identified by banks, though not all of 

 

10 The International Banking Act of 1978 allowed foreign banking organizations (FBO) the option to 

conduct banking operations in the U.S. through a branch or agency chartered by OCC. A federal 

branch is an FBO’s office licensed by OCC to exercise such banking powers as accepting deposits 

and operating as a fiduciary. 11 The Federal Deposit Insurance Act defines an IAP as (1) any director, officer, employee, or 

controlling stockholder (other than a bank holding company or savings and loan holding company), 

of, or agent for an insured depository institution; (2) any other person who has filed or is required to 

file a change-in-control notice with the appropriate federal banking agency under section 7(j); 

(3) any shareholder (other than a bank holding company or savings and loan holding company), 

consultant, joint venture partner; and any other person as determined by the appropriate federal 

banking agency (by regulation or case-by-case) who participates in the conduct of the affairs of an 

insured depository institution; and (4) any independent contractor (including any attorney, appraiser, 

or accountant) who knowingly or recklessly participates in (a) any violation of any law or regulation; 

(b) any breach of fiduciary duty; or (c) any unsafe or unsound practice, which caused or is likely to 

cause more than a minimal financial loss to, or a significant adverse effect on, the insured 

depository institution. Relating to IAP relationships, OCC primarily pursues actions related to the 

following identifiers: director, officer, employee, agent, and owner (or controlling shareholder) which 

we will refer to collectively as bank insiders throughout this report.
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these would meet the criteria for the Fast Track program or lead to 

a prohibition, if processed. 

We found that OCC’s examination procedures reasonably address

the prevention and detection of criminal activities by bank insiders

if performed as warranted during ongoing safety and soundness 

examinations. OCC examiners employ a risk-based supervisory 

approach focused on evaluating risk, identifying problems, and 

ensuring banks take appropriate corrective action. As part of this 

approach, OCC examiners stated that they review bank internal 

control and audit functions. OCC also tracks its supervisory actions 

for any deficiencies it identifies during these examinations. When 

irregularities or potential fraud are identified during an examination, 

it is the bank’s duty to submit a timely SAR, which notifies law 

enforcement, and OCC. The banks conduct their own 

investigations, and OCC will follow up with banks and provide any 

back up banks may need. OCC also performs pre-employment 

screening at banks in certain circumstances. Appendix 2 provides 

more details of these procedures.

We reviewed Fast Track’s processes in pursuing 1818 and 1829 

prohibition actions against bank insiders. Based on our review of 

documentation and interviews with the program coordinator, we 

concluded that they consistently followed the applicable policies 

and procedures. However, we concluded that Fast Track was not 

as efficient and effective in pursuing prohibitions as it could be.

Finding OCC Should Assess Fast Track

We found that Fast Track had not been assessed since 2009 and 

did not include the establishment of specific performance metrics 

or an analysis of staffing levels needed to meet program goals.

We also concluded that Fast Track’s staffing model limited the 

number of cases Fast Track could process.

Fast Track Staffing and Training

According to OCC officials, Fast Track could benefit from

additional and permanent staffing. Thirteen (13) law department 

support staff process Fast Track case files, including one full-time 

program coordinator and 12 law-department support staff who

process Fast Track case files on a voluntary part-time basis once 
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their primary duties are addressed. These individuals undergo Fast 

Track training and must demonstrate competence to perform the 

work satisfactorily, which leads to an OCC certification as a Fast 

Track Processor I or II. 

OCC’s law department’s senior management determined the 

staffing levels. Prior to 2009, most 1829 and 1818 cases were 

developed by one lead Fast Track coordinator. In 2009, the 

program was expanded to permit other support staff in the law 

department to participate on a voluntary basis. It was at that time 

the positions of Fast Track processor I and II were developed. 

Volunteers for these positions were advertised on the OCC’s 

internal opportunities board as a developmental opportunity for law 

department support staff in headquarters and the four main district 

offices.

When asked how it was determined that the Fast Track staffing 

level was appropriate, we were told that although the program has 

undergone significant changes through the years, which 

necessitated staffing considerations, there has never been a formal 

written assessment of staffing levels. OCC officials stated that 

except for the Fast Track coordinator, all other personnel who 

worked on the Fast Track program have other primary duties that 

take up most of their time. Furthermore, OCC has not established 

specific performance measures for the number of 1818 or 1829 

cases to be processed by Fast Track each year, which could be 

used as a basis in determining the right number of staffing for the 

program results that management wants to achieve.

Given the limited staff and high number of SARs downloaded into 

its SAR Fast Track database by OCC, many cases were either 

never assigned or delayed in being assigned to processors. OCC 

downloaded approximately 48,500 SARs received by FinCEN 

related to bank insiders during calendar years 2009 through 2011. 

According to a Fast Track report, 12,102 of the 48,500 SARs met 

the $5,000 threshold for selection and assignment to processors.

However, during that time, Fast Track only processed 554 of the 

12,102 SARs, leaving more than 95 percent of the SARs

unassigned or unprocessed. That said, not all of the unassigned or 

unprocessed cases would have met the Fast Track criteria for 

either an 1829 letter or 1818 prohibition.
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OCC’s PPM 5310-8 and its program procedures manual do not 

specify how long it should normally take to process a prohibition 

action (1829 prohibition letter or 1818 prohibition order). Of the 42 

prohibition actions we sampled, 33 (nearly 80 percent) were issued 

in less than a year, ranging from 2 to 307 days; and 9 letters were 

issued in more than a year, ranging from 432 to 993 days. The 

program coordinator told us that some of the more lengthy 

processing times were primarily due to waiting on criminal 

authorities to prosecute the criminal case, the processors being 

busy with other primary work responsibilities, or not receiving all 

the necessary documents related to court cases. The two 1818 

prohibition orders in our sample, which involve additional research 

and procedures, took 269 and 442 days to be processed. 1818 

prohibition orders generally take a longer time to process as OCC 

needs to generate detailed and sufficient evidence, rather than rely 

on the criminal process as is with the 1829 letters, and be 

prepared to litigate the case if the bank insider does not settle.

We noted that Fast Track could also benefit from additional training 

relating to the processing of 1818 prohibition orders. Although 

1818 prohibition orders require additional work, they prohibit 

individuals not already prohibited by law. In these cases, the 

individual has not been convicted, but there is an admission of 

wrongdoing or clear evidence of wrongdoing;

12 and prosecution of 

the individual has been declined13 or is otherwise not being actively 

pursued by criminal law enforcement. An OCC official informed us 

that Fast Track primarily focuses on processing 1829 prohibition 

letters. During calendar years 2009 through 2011, 510, or 92 

percent, of the 554 prohibition actions processed were 1829

prohibition letters and the remaining 44 were 1818 prohibition 

orders. However, individuals are already prohibited from working in 

the banking industry under 1829 once they have been convicted or 

 

12 In development of 1818 prohibition order cases, admission of wrongdoing or clear evidence of 

wrongdoing may be obtained from the: (1) SAR, (2) bank records, (3) court records, or (4) Public 

Access to Court Electronic Records (PACER) Service. PACER is an electronic public access service 

that allows users to obtain case and docket information online from federal appellate, district, and 

bankruptcy courts, and the PACER Case Locator, found at www.pacer.gov/. 13 Law enforcement agencies may decline to prosecute bank employees for their activities if the case 

does not meet prosecutorial guidelines (e.g., dollar amount of loss), or restitution has been made, or 

an employee’s actions does not constitute a strong case of criminal law violation. In such cases, the 

employee’s actions may still constitute an act of significant wrongdoing that may serve as a basis for 

an administrative enforcement action by the OCC against an employee.
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have entered into a pretrial diversion program for a crime involving 

dishonesty or breach of trust. An OCC official told us that the 

volunteer staff members would need additional training14 to 

process more of the complex 1818 prohibition orders.

We inquired as to why OCC issued 1829 prohibition letters given 

that the recipient of the letters were already banned from banking 

by 1829. According to an OCC official, the 1829 prohibition letters 

are useful in notifying the individuals that they are prohibited and 

that there is a criminal penalty for re-entering the banking industry. 

An 1829 prohibition letter can be used as evidence if an individual 

attempts to re-enter the banking industry. In addition, the 1829 

prohibition letters are posted in a database on OCC’s website so 

that banks can determine if a job applicant has been prohibited. 

The OCC official also told us that he would like to see more 1818 

prohibition orders pursued, but without reducing the number of

1829 prohibition letters issued. The official further stated that 

there are two potential ways to increase the effectiveness of the 

program: increasing the number of Fast Track processors focused

on developing 1818 prohibition order cases or allowing OCC 

attorneys to develop 1818 prohibition order cases using 

information from the SARs. In the past, attorneys used SARs to 

develop 1818 cases on their own. However, the current structure 

of the program relies solely upon the Fast Track coordinator and

volunteer support staff qualified as Fast Track processors to take 

the initial steps needed to develop 1818 cases from SARs. OCC 

officials informed us that, going forward, the E&C Division may 

consider changes, as appropriate, and in a matter consistent with 

the demands in the department, to make the program even more 

effective than it has been.

 

14 An individual would need additional training to be able to demonstrate proficiencies related to tasks 

such as: (1) conducting legal research by maneuvering in the various databases used in Fast Track; 

(2) communicating effectively in order to obtain detailed information from bank contacts, law 

enforcement entities; (3) examining bank documents to determine if there is sufficient evidence to 

support an 1818; (4) constructing an introduction letter to the employee; (5) communicating with 

the employee or their legal counsel in response to the introduction letter; (6) understanding when and 

how to follow-up with the bank investigator; and (7) drafting a Washington Supervisory Review 

Committee memo.
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Monitoring and Assessing for Improvement

The Government Performance and Results Modernization Act of 

2010 (GPRMA)15 requires agencies to set long-term goals and 

objectives as well as specific, near-term performance goals. 16

Agency leaders at all levels of the organization are accountable for 

choosing goals and indicators wisely and for setting ambitious, yet 

realistic targets. Wise selection of goals and indicators should 

reflect careful analysis of the characteristics of the problems and 

opportunities to influence and to advance an agency mission, 

factors affecting those outcomes, agency capacity and priorities.

The GPRMA further requires agencies to measure performance 

against those goals and report publicly on progress. This includes 

for each agency goal: (1) reviewing the progress achieved during 

the most recent quarter, overall trend data, and the likelihood of 

meeting the planned level of performance; and (2) assessing 

whether relevant organizations, program activities, regulations, 

policies, and other activities are contributing as planned to the 

agency priority goals.

According to OCC officials, Fast Track does not have specific

performance metrics to monitor the program’s results. Rather, the 

officials told us that OCC publishes enforcement action statistics 

for OCC in its annual report. With regard to the number of 1818 

cases listed each year in the annual report, some, but not all, come 

from Fast Track. By contrast, all of the 1829 cases are generated 

through Fast Track. In addition, according OCC officials, Fast Track 

does not track the number of hours each case takes to process 

since, depending on the circumstances, each case varies on the 

time needed to be processed.

According to an OCC official, the last time OCC assessed Fast 

Track was in 2009, when the program was expanded to permit 

 

15 Public Law 111- 352. 16 Office of Management and Budget Circular No. A-11, Preparation, Submission, and Execution of the 

Budget (A-11), “organizational components of agencies are not considered independent 

establishments, but rather are a part of them. A-11 further states that agencies should work with 

their components to implement the GPRA Modernization Act in a manner that is most useful to the 

whole organization. Agencies are expected to work with their components to identify priorities, 

goals, performance indicators, and other indicators relative to the mission and strategic objectives of 

the agency.”
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Chief Counsel Office support staff to participate as either Fast 

Track I or II processors. We were told the assessment did not 

include the establishment of specific performance metrics or an 

analysis of staffing levels needed to meet program goals. 

Significant conforming changes were made to Fast Track’s program 

manual and PPM 5310-8 during that time. When asked about the 

overall effectiveness of the program, OCC officials told us that they

believe the program has been successful because it has allowed 

the agency to generate many 1829 letters through the years, as 

well as to supplement the number of 1818 prohibition cases. 

Conclusion

With internal fraud and unethical conduct within banks being of 

particular concern because of the position that banks hold in the 

financial system, it is essential that proper controls and procedures 

are in place relating to criminal activities by bank insiders. Banks, 

FinCEN, and OCC all play key roles in the prevention, detection, 

and reporting of internal bank criminal activities. Banks providing 

SARs to FinCEN, which in turn, are then downloaded by OCC into 

its SAR Fast Track database, provide great opportunity to take 

action against bank insiders who try to benefit from unethical 

behavior. With the establishment of Fast Track and the 

examination procedures in place, OCC was able to take 

enforcement actions against some of these insiders. That said, Fast 

Track could make a larger impact by processing more 1818 

prohibition cases that would ban more unethical bank insiders from 

working in the banking industry. 

Recommendation

We recommend that the Comptroller of the Currency assess Fast 

Track to determine whether the program’s efficiency and 

effectiveness can be increased. This assessment should include, 

but is not limited to, the program’s purpose and goals, 

comprehensive requirements, performance results over time, 

current staffing levels, and additional training needs.
OCC’s Fast Track Enforcement Program Should Be Assessed Page 15

(OIG-17-006)

Management Response

OCC management agreed with our recommendation and stated that 

it will complete an assessment of Fast Track by September 30, 

2016.

Office of Inspector General Comment

Management response meets the intent of our recommendation.

* * * * * *

We appreciate the courtesies and cooperation provided to our staff 

during the audit. If you wish to discuss the report, you may 

contact me at (202) 927-5776 or Fawntrella Thompson, Auditor-inCharge, at (202) 927-5512. Major contributors to this report are 

listed in Appendix 5.

/s/

Susan Barron

Audit Director

Appendices
Appendix 1

U.S. Attorney’s Office, District of Minnesota News Release 

OCC’s Fast Track Enforcement Program Should Be Assessed Page 16 

(OIG-17-006)

Auditor’s Note: This appendix is a news release by the U.S. 

Attorney’s Office, District of Minnesota, announcing the sentencing 

of two individuals for their role in a $50 million bank fraud 

conspiracy.

Leader of $50-Million Fraud Ring Sentenced

FOR IMMEDIATE RELEASE

August 13, 2012

MINNEAPOLIS – Earlier today in federal court in Minneapolis, a 

California man and a New York man were sentenced for their roles in 

a $50-million bank fraud conspiracy that operated in six states, 

involved a network of bank employees, and victimized more than 

500 individuals around the world by stealing their personal and 

financial information. The operation, deemed one of the largest and 

most sophisticated of its kind prosecuted in the U.S. to date, was 

carried out between 2006 and 2011 in Minnesota, California, 

Massachusetts, Arizona, New York, and Texas. United States 

District Court Chief Judge Michael J. Davis sentenced Julian 

Okeayaninneh, age 44, of Colton, California, the leader of the 

operation, to 324 months in federal prison on one count of bank 

fraud conspiracy, 11 counts of bank fraud, six counts of mail fraud, 

two counts of wire fraud, four counts of aggravated identity theft, 

one count of money laundering conspiracy, and one count of 

trafficking in false authentication features. In handing down the 

sentence, Judge Davis said, “This is one of the largest frauds I’ve 

ever seen. The sophisticated means used and the use of bank 

insiders in this fraud is troubling to the court. You are the leader, and 

it’s a sad day that I have to send someone to prison for such a long 

time. But you deserve the sentence you receive.”

Earlier in the day, Judge Davis sentenced Olugbenga Temidago 

Adeniran, age 36, of New York, to 266 months in federal prison on 

one count of bank fraud conspiracy, four counts of bank fraud, and 

four counts of aggravated identity theft. The two men were charged 

in a superseding indictment on June 7, 2011. They were convicted 

on February 28, 2012, following a three-week trial. Because the 

federal criminal justice system does not have parole, the men will 

spend virtually their entire sentences behind bars. 
Appendix 1

U.S. Attorney’s Office, District of Minnesota News Release 

OCC’s Fast Track Enforcement Program Should Be Assessed Page 17

(OIG-17-006)

Following today’s sentences, U.S. Attorney B. Todd Jones said, 

“As part of this conspiracy, crooked bank insiders bartered the 

personal financial information of their patrons. This violation of 

trust clearly threatens the confidence the public has traditionally 

placed in our financial institutions and cannot be tolerated. Today’s 

sentences send a clear message to those identity thieves and 

fraudsters who conspire with dishonest bank employees to wreak 

havoc on the personal finances of innocent customers.”

Louis Stephens, Special Agent in Charge of the local office of the 

U.S. Secret Service, added, “The sentences issued send an 

unmistakably strong message about the way our courts view this 

type of criminal activity. These defendants were leaders and 

members of a complex criminal conspiracy with an organizational 

hierarchy and effectiveness much like traditional organized crime. 

The successful investigation of this case represents a strong 

victory for the people of Minnesota and the integrity of the 

financial infrastructure of the United States.”

The evidence presented at trial proved that from 2006 through 

March of 2011, Okeayaninneh and Adeniran acted in concert with 

numerous co-conspirators to buy and sell stolen bank-customer 

information that was ultimately used to open fraudulent bank and 

credit card accounts, apply for loans, and obtain cash. 

Subsequently, co-conspirators altered checks for deposit into those 

fraudulent accounts and drafted checks against them. They also 

acquired cash from the fraudulent credit card accounts they 

established and used the false credit cards to purchase 

merchandise. Moreover, they co-opted home equity lines of credit 

without the knowledge or consent of the true account holders, 

using the lines of credit for their personal benefit. In addition to 

recruiting bank employees to assist in the scheme, co-conspirators 

regularly recruited other individuals to conduct fraudulent financial 

transaction, often transporting them to various banks around the 

country to commit their crimes.

The financial institutions victimized included American Express, 

Associated Bank, Bank of America, Capital One, Guaranty Bank, JP 

Morgan Chase Bank, TCF Bank, US Bank, Wachovia Bank, 

Washington Mutual, and Wells Fargo Bank. They provided 
Appendix 1

U.S. Attorney’s Office, District of Minnesota News Release 

OCC’s Fast Track Enforcement Program Should Be Assessed Page 18

(OIG-17-006)

extensive cooperation and assistance throughout the course of the 

investigation and prosecution of this case. 

This case resulted from an on-going investigation, dubbed 

Operation Starburst. The investigation was led by the Minnesota 

Financial Crimes Task Force, which was established pursuant to 

state law. The task force investigates financial crimes related to 

identity theft, with a special emphasis on organized criminal 

enterprises. It is comprised of local, state, and federal law 

enforcement investigators dedicated to combating the growing 

trend of cross-jurisdictional financial crimes. Among them are 

agents from U.S. Secret Service and IRS—Criminal Investigations. 

“Putting these criminals and their cohorts behind bars will prevent 

many more Minnesotans from becoming identity theft victims,” 

said Patrick Henry, task force commander, of the Minnesota Bureau 

of Criminal Apprehension. “Today’s sentencings send a clear 

warning to those who would target Minnesotans for identity theft 

that this task force and its partners are diligent in investigating 

these crimes even when they are being committed from beyond our 

borders.” 

“Investigating identity theft is a priority for IRS Criminal 

Investigations,” added Kelly Jackson, Special Agent in Charge of 

the IRS-Criminal Investigations’ St. Paul Field Office. “Stealing 

identities is a serious crime that hurts many innocent people. IRSCriminal Investigations, along with our law enforcement partners 

and the U.S. Attorney’s Office, remain vigilant in identifying, 

investigating and prosecuting those individuals who seek to 

willfully defraud U.S. citizens and have a blatant disregard for the 

victims of their schemes.”

Trial testimony proved that Adeniran was a high-level manager in 

the conspiracy. He directed operations and routinely traveled to 

Minnesota to obtain cash from banks and purchase merchandise 

from Mall of America and Southdale Mall with the use of fraudulent 

credit cards. Okeayainneh, however, was the leader of the 

conspiracy. After his arrest, authorities found more than 8,000 

stolen identifiers in his storage locker, including hospital records, 

bank records, credit reports, commercial checks, credit card 

mailers, and motor vehicle information. According to trial 

testimony, the stolen information was used to create false 
Appendix 1

U.S. Attorney’s Office, District of Minnesota News Release 

OCC’s Fast Track Enforcement Program Should Be Assessed Page 19

(OIG-17-006)

identification documents, sometimes in less than an hour. 

Okeayainneh, himself, had 27 fraudulent driver’s licenses bearing 

his photography. At the time of his arrest, he also possessed more

than 140 photos of co-conspirators, including Adeniran, ready to 

be attached to false identification. In addition, he had check stock 

and blank American Express credit cards for use in making false 

financial instruments.

During the life of the conspiracy, Okeayainneh commanded the 

managers and foot soldiers in the operation to commit the fraud, 

which afforded him layers of protection from exposure as the 

actual leader of the ring. He directed a legion of people, some of 

whom provided him with stolen personal identifiers, while others 

used that information to create false identification. Then, armed 

with those false identification documents and fraudulent financial 

instruments, co-conspirators traveled the country, committing fraud 

on behalf of the conspiracy.

Status of Co-conspirators—

On July 20, 2012, Fawsiyo Hassan Farah, age 43, of Brooklyn 

Park, a former personal banker at Wells Fargo Bank, was sentenced 

to 33 months in prison on one count of aiding and abetting bank 

fraud and one count of aiding and abetting aggravated identity 

theft. She was charged in a superseding indictment on June 7, 

2011, and pleaded guilty on August 15, 2011.

On August 6, 2012, Charles Tubman Dwamina, age 47, of Lino 

Lakes, a former personal banker at Wells Fargo Bank, was 

sentenced to 12 months and one day on one count of aiding and 

abetting bank fraud. He pleaded guilty on January 6, 2012.

Jonathan Sie Earley, age 50, of Brooklyn Center, will be sentenced 

this afternoon. On June 14, 2011, he pleaded guilty to one count 

of aiding and abetting bank fraud and one count of aggravated 

identity theft. 

Jude Obira Okafor, age 46, of Fridley, will be sentenced tomorrow. 

On December 19, 2011, he pleaded guilty to one count of aiding 

and abetting bank fraud. He faces a potential maximum penalty of 

30 years in prison. 
Appendix 1

U.S. Attorney’s Office, District of Minnesota News Release 

OCC’s Fast Track Enforcement Program Should Be Assessed Page 20

(OIG-17-006)

Sundayga Dexter Roberts, age 48, of Brooklyn Park, a former 

personal banker at Wells Fargo Bank and Associated Bank, will be 

sentenced tomorrow. On September 6, 2011, he pleaded guilty to 

one count of aiding and abetting bank fraud and one count of 

aiding and abetting aggravated identity theft. For his crimes, 

Roberts faces a potential maximum penalty of 30 years on the 

bank fraud charge and a consecutive mandatory minimum penalty 

of two years on the aggravated identity theft charge.

Adetokunbo Olubunmi Adejumo, age 35, of Osseo, will be 

sentenced tomorrow. On July 26, 2011, he pleaded guilty to one 

count of aiding and abetting bank fraud and one count of aiding 

and abetting aggravated identity theft. He faces a potential 

maximum penalty of 30 years on the bank fraud charge and a 

consecutive mandatory minimum penalty of two years on the 

aggravated identity theft charge.

Three co-defendants remain fugitives: Charles Amankwah Akuffo, 

age 31, no known address; Oladipo Sowunmi Coker, age 31, of 

Minneapolis; and Betty White, of Los Angeles, California. Akuffo 

was charged with one count of bank fraud conspiracy, three 

counts of bank fraud, and three counts of aggravated identity 

theft. Coker was charged with one count of bank fraud conspiracy, 

11 counts of bank fraud, seven counts of mail fraud, six counts of 

aggravated identity theft, and one count of money laundering 

conspiracy. White was charged with one count of bank fraud 

conspiracy, five counts of bank fraud, and one count of aggravated 

identity theft.

The Minnesota Financial Crimes Task Force serves the entire 

District of Minnesota, presenting its cases to county or federal 

prosecutors, as appropriate. Its participants include the U.S. Secret 

Service, the U.S. Postal Inspection Service, U.S. Immigration and 

Customs Enforcement’s Homeland Security Investigations, the 

Internal Revenue Service—Criminal Investigations, the Social 

Security Administration, the U.S. Department of Treasury—Office 

of Inspector General, the Federal Deposit Insurance Corporation—

Office of Inspector General, the Minneapolis Police Department, the 

Edina Police Department, the Baxter Police Department, the Duluth 

Police Department, the Wright County Sheriff’s Office, the Ramsey 
Appendix 1

U.S. Attorney’s Office, District of Minnesota News Release 

OCC’s Fast Track Enforcement Program Should Be Assessed Page 21

(OIG-17-006)

County Sheriff’s Office, the Mille Lacs County Sheriff’s Office, and 

the Minnesota Bureau of Criminal Apprehension.

In this case, the task force was assisted by the police department 

in Eau Claire, Wisconsin, and the Las Vegas metropolitan police, as 

well as other law enforcement agencies across the country. The 

case was prosecuted and tried by Assistant U.S. Attorneys Ann M. 

Anaya and Lola Velazquez-Aguilu. 

The task force and the Minnesota U.S. Attorney’s Office want to 

remind people to protect themselves from identity theft. For more 

information, visit www.stopfraud.gov/protect-identity.html.

In separate but related cases, many of which were developed and 

charged early on in the investigation, numerous defendants have 

pleaded guilty and a number of them have already been 

sentenced—

On August 2, 2012, Borode Ayinde Akinropo was sentenced to 

time served on one count of bank fraud and one count of 

aggravated identity theft. Akinropo was charged on March 30, 

2011, and pleaded guilty on June 7, 2011.

On July 12, 2012, Angela Kay Grigsby was sentenced to time 

served on one count of bank fraud and one count of aggravated 

identity theft. She was charged on January 12, 2011, and pleaded 

guilty on January 24, 2011. She was a foot soldier for the 

conspiracy, conducting fraudulent financial transactions on its 

behalf.

Also on July 12, 2012, Michael Kweku Asibu, a former banker at 

Bremer Bank and Associated Bank, was sentenced to 42 months in 

federal prison on one count of bank fraud and one count of 

aggravated identity theft. He was charged on November 23, 2011, 

and pleaded guilty on December 14, 2011.
Appendix 2 

OCC Examination Procedures Relating to Criminal Activities 

OCC’s Fast Track Enforcement Program Should Be Assessed Page 22 

(OIG-17-006)

The Office of the Comptroller of the Currency’s (OCC) risk-based 

supervisory approach requires OCC examiners to determine how 

certain existing or emerging issues for a bank affect the nature and 

extent of risk in that institution. Evaluating a bank’s system of 

internal controls, as well as its audit function, is essential to 

identifying risks. The following are procedures OCC examiners 

stated are performed, as warranted, related to internal control 

processes and audit functions, as well as expanded procedures if 

areas of concerns relating to internal criminal activities arise: 

Review of Banks’ Internal Control Processes: 

Examiners assess and draw conclusions about the adequacy of a 

bank’s internal control during every supervisory cycle, which may 

include the following procedures:

• determining the scope, type, and depth of an internal control 

review based on the bank’s size, complexity, scope of 

activities, and risk profile, as well as on OCC’s assessment 

of the bank’s audit functions; 

• performing validations, which may encompass inquiry, 

observation, and testing of the bank’s control systems;

• using questionnaires as part of their assessments of internal 

control; 

• reviewing banks’ policies and procedures on insider 

activities; and/or

• reviewing Suspicious Activity Reports (SARs) at banks, as 

necessary, depending on the issues identified.

Banks’ Audit Functions:

OCC examiners assess banks’ overall audit function during each 

supervisory cycle, which include the following procedures: 

• drawing an overall conclusion about the adequacy and 

effectiveness of the overall audit program and the board of 

directors’ oversight of the audit program; and 
Appendix 2

OCC Examination Procedures Relating to Criminal Activities 

OCC’s Fast Track Enforcement Program Should Be Assessed Page 23

(OIG-17-006)

• assigning a rating of strong, satisfactory, or weak to the 

overall audit program;

• focusing on the sufficiency of the banks’ internal audit and 

audit programs and their processes to ensure that the banks 

have sufficient controls in place and are up-to-date on 

current issues to maintain safe and sound practices; and

• performing a quarterly review at banks, which includes 

review of audit reports and board minutes for discussions of 

insider activities.

Following risk evaluations, OCC examiners tailor supervisory 

activities to the risks identified. For areas of higher risk, such as 

when a specific instance is identified indicating possible 

wrongdoing by a bank employee, OCC examiners expand the 

procedures they perform.17 These expanded procedures may result 

in the recommendation of corrective actions if deficiencies are 

noted during an examination. If a deviation is severe and not in 

accordance with sound banking policy, OCC will issue a matter 

requiring attention, which must be addressed within a deadline set 

by OCC. OCC monitors any deficiencies noted, as well as the 

related corrective actions, and enters the information in a database.

OCC examiners review banks’ internal audit reports. Upon review 

of the reports, OCC examiners go where the leads take them. OCC 

examiners look (1) for controls that are in place at the bank, (2) at 

the bank’s external audit report, and (3) to determine if the bank’s 

methods are effective. OCC requires the bank to have an audit that 

includes a review of the controls, and if OCC has concerns, they 

will conduct their own review.

OCC looks to banks to do their best to uncover irregularities or 

fraud by their own internal auditors and correct issues before OCC 

has to step in. There have been times when OCC suggests to a 

bank to hire a forensic auditor. OCC examiners conduct oversight 

to monitor how banks are regulating their operations and when 

irregularities or fraud are found, it is the bank’s duty to submit a 

completed SAR, notify law enforcement, and notify OCC. After 

 

17 Due to the nature of OCC’s risk-based supervisory approach in identifying possible areas of concerns 

relating to internal criminal activities at banks, and scope limitations of our review, we did not select 

a sample of OCC examinations to determine whether expanded procedures were performed.
Appendix 2

OCC Examination Procedures Relating to Criminal Activities 

OCC’s Fast Track Enforcement Program Should Be Assessed Page 24

(OIG-17-006)

which time, the bank conducts its own investigation and OCC 

examiners will follow up with the bank and provide support to the 

bank.

OCC’s Performance of Pre-Employment Screening:

OCC reviews certain banks’ hiring processes, including the conduct 

of pre-employment screenings, depending on the size and 

complexity of the bank. OCC requires that problem banks with a 3, 

4, or 5 composite CAMELS18 rating have an extensive screening 

process when hiring new bank officers or directors. For instance, 

before a bank hires the officer or director, the bank must provide 

OCC with a 914 packet (notice of intent to hire) on the individual. 

A further background check is done at the district level. Once this 

more extensive background check is complete then OCC will hold a 

consult with legal in Denver to determine if the hire would be a 

good move for the bank in safe and sound practices, especially if 

the individual is coming from another troubled bank.

OCC’s process is designed to make sure that: (1) the individual is 

not responsible for the composite rating of the bank he/she is 

coming from, and (2) the individual is truly fit and qualified for such 

a position as officer or director. If an individual applies for such a 

position and is found to have been the reason the failure of the 

previous bank of employment; OCC will give that individual the 

option to withdraw his/her application.

 

18 CAMELS is an acronym for a bank’s performance rating components: Capital adequacy, Asset 

quality, Management, Earnings, Liquidity, and Sensitivity to market risk. Numerical values range 

from 1 to 5, with 1 being the highest rating and 5 representing the worst rated banks.
Appendix 3

Objectives, Scope, and Methodology

OCC’s Fast Track Enforcement Program Should Be Assessed Page 25 

(OIG-17-006)

The objectives of our audit were to: (1) identify the extent and 

nature of criminal and other suspicious activity committed by bank 

insiders reported to Financial Crimes Enforcement Network

(FinCEN) under the Bank Secrecy Act through a review of 

Suspicious Activity Reports (SARs) and related analytical studies; 

(2) identify Office of the Comptroller of the Currency (OCC) 

processes for pursuing enforcement actions against current or 

former bank insiders for which there is evidence of wrongdoing 

involving dishonesty, a breach of trust, or money laundering; 

(3) identify OCC examination procedures to ensure banks have 

sufficient processes to prevent, detect, and report internal criminal

activities; (4) determine whether the procedures are applied; and 

(5) determine whether deficiencies identified during the 

examination process result in supervisory actions that are tracked. 

The scope of our audit ranged from calendar years 2009 through 

2011.

We conducted our fieldwork in Washington, D.C. between 

December 2011 and June 2016, which included the following: 

FinCEN

To accomplish objective 1 of this audit, specifically, we

• interviewed the following FinCEN officials: the Assistant 

Director for the Office of Regulatory Analysis; the Deputy 

Assistant Director of Data Analysis; and the Audit Liaison; 

• reviewed FinCEN’s policies and procedures for collecting and 

sharing SAR data with OCC; 

• reviewed FinCEN’s revised SAR form to gain an understanding 

of its content and instructions; 

• reviewed a SAR data download from FinCEN for the period of 

January 2009 – December 2011; 

• reviewed FinCEN SAR Stats reports (formerly known as SARs 

By the Numbers reports), which sorts the number of SARs in 

various ways based on the categories marked on the SARs 

when filed by banks; 
Appendix 3

Objectives, Scope, and Methodology

OCC’s Fast Track Enforcement Program Should Be Assessed Page 26

(OIG-17-006)

• reviewed Exhibit 6 - SAR Filings by Primary Federal Regulator, 

of the FinCEN SAR Stats reports to ascertain the total number 

of SARs filed by banks, as well as the number of SARs filed by 

banks whose primary regulators are OCC or the legacy Office 

of Thrift Supervision (OTS). The exhibit includes the following 

federal regulators/categories from the SAR form: Federal 

Reserve Board, Federal Deposit Insurance Corporation, OCC, 

OTS, National Credit Union Administration; Unspecified, Money 

Services Businesses (bank form filings), and Office of Foreign 

Asset Control filings. During 2009–2011, FinCEN received 

approximately 2.2 million SARs from banks, of which, 

approximately 1.3 million were filed by banks regulated by 

OCC or the former OTS; and

• reviewed Exhibit 7 - Relationship to Financial Institution, of the 

FinCEN SAR Stats reports, to ascertain the number of

Institution-Affiliated Party (IAP) relationships identified on the 

SARs. The exhibit includes the following 13 relationship 

types/categories: accountant, agent, appraiser, attorney, 

borrower, broker, customer, director, employee, officer, 

shareholder, other, and none indicated, for all federal 

regulators. Multiple relationships to banks are identified on 

some SARs. This exhibit does not break out these relationships 

by federal regulators. For the scope of our review, on the 

approximately 2.2 million total SARs filed, there were 

approximately 3.9 million relationships identified by banks, of 

which approximately 53,000 were related to bank directors, 

employees, and officers.

OCC

To accomplish objectives 2 through 5, specifically, we

• reviewed applicable laws, rules, and regulations that the banks 

and OCC must follow relating to the prevention, detection, and 

reporting requirements for criminal activity committed by bank 

insiders;

• reviewed OCC’s policies and procedures, as well as OCC 

guidance issued to the banks related to the prevention, 

detection, and reporting requirements for criminal activity 

committed by bank insiders;
Appendix 3

Objectives, Scope, and Methodology

OCC’s Fast Track Enforcement Program Should Be Assessed Page 27

(OIG-17-006)

• interviewed a Department of Justice Assistant United States 

Attorney;

• interviewed the following OCC headquarter officials regarding 

bank and OCC responsibilities and activities relating to the 

prevention, detection, and reporting requirements for criminal 

activity committed by bank insiders: the Director and Special 

Counsel within the Enforcement and Compliance Division; the 

Director, former Director, and staff within Operational Risk 

Policy Division; the Director with the Bank Information 

Technology Division; the Director, an external fraud specialist, 

and other officials in the Special Supervision Division; the Fast 

Track program coordinator; and Assistant Deputy Comptrollers 

from various field offices (Wichita, Kansas; San Francisco, 

California; Minneapolis, Minnesota; and Birmingham, Alabama); 

a District Fraud Expert in the New England District; and OCC’s 

webmaster;

• documented OCC’s Fast Track Enforcement Program (Fast 

Track) processes for identifying suspicious activities relating to 

bank insiders and for issuing prohibition actions under 

12 U.S.C. 1829 and 12 U.S.C. 1818;

• obtained documentation to ascertain the total number of SARs 

received, the number of IAP relationships reported, and the 

number of SARs that meet the criteria for pursuing 

enforcement actions. OCC sorts the SARs based on the 

following IAP relationships: director, officer, employee, agent, 

and owner (or controlling shareholder);

• compared the total number of SARs downloaded by OCC to the 

number received by FinCEN; and

• sampled 45 of 554 Fast Track case files that were extracted 

from OCC’s website, as a test of controls over the documented 

processes above to determine whether the processes were 

consistently followed. We used the Government Accountability 

Office/President’s Council on Integrity and Efficiency’s 

Financial Audit Manual as criteria for the acceptable number of 

deviations in sampling control tests to conclude on the results 

of the statistical sampling test.
Appendix 3

Objectives, Scope, and Methodology

OCC’s Fast Track Enforcement Program Should Be Assessed Page 28

(OIG-17-006)

We conducted this performance audit in accordance with generally 

accepted government auditing standards. Those standards require 

that we plan and perform the audit to obtain sufficient, appropriate 

evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the 

evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix 4 

Management Response

OCC’s Fast Track Enforcement Program Should Be Assessed Page 29 

(OIG-17-006)
Appendix 4

Management Response

OCC’s Fast Track Enforcement Program Should Be Assessed Page 30

(OIG-17-006)
Appendix 5

Major Contributors to This Report

OCC’s Fast Track Enforcement Program Should Be Assessed Page 31 

(OIG-17-006)

Fawntrella Thompson, Auditor-in-Charge

Jeremy Spears, Auditor

Kiira Hall, Referencer
Appendix 6 

Report Distribution

OCC’s Fast Track Enforcement Program Should Be Assessed Page 32 

(OIG-17-006)

The Department of the Treasury

 

Deputy Secretary

Office of Strategic Planning and Performance Improvement

Office of the Deputy Chief Financial Officer, Risk and Control 

Group

Office of the Comptroller of the Currency

Comptroller of the Currency

Liaison Officer

Financial Crimes Enforcement Network

Director

Liaison Officer

Office of Management and Budget

 Office of Inspector General Budget Examiner
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