
The Comptroller of the Currency of the United States of America (“Comptroller”), through his national bank examiners and other staff of the Office of the Comptroller of the Currency (“OCC”), conducted examinations of U.S. Bank National Association, Cincinnati, OH (“Bank”). The OCC identified deficiencies in the Bank’s Bank Secrecy Act/anti-money laundering (“BSA/AML”) compliance program that resulted in violations of 12 U.S.C. § 1818(s) and its implementing regulation, 12 C.F.R. § 21.21, 12 C.F.R. § 21.11, and 31 U.S.C. § 5318(i) and its implementing regulation, 31 C.F.R. § 1010.610, and informed the Bank of the findings resulting from the examinations. The OCC issued a Consent Cease and Desist Order for the BSA/AML deficiencies on October 23, 2015 (“2015 Consent Order”)