The National Iron Bank of Salisbury, Connecticut entered an OCC Formal Agreement dated July 11, 2023 for unsafe and unsound practices across capital and strategic planning, concentrations risk management, credit underwriting and administration, and BSA/AML risk management — as well as violations of the Bank Secrecy Act.

The National Iron Bank — OCC Formal Agreement: BSA/AML and Risk Management (2023)

Outcome: The National Iron Bank, headquartered in Salisbury, Connecticut, entered an OCC Formal Agreement dated July 11, 2023 for a combination of unsafe or unsound banking practices spanning capital and strategic planning, credit concentration risk management, credit underwriting and administration, and BSA/AML risk management — as well as specific violations of the Bank Secrecy Act.

The National Iron Bank is a small community bank in Salisbury, Connecticut (Litchfield County). The July 2023 OCC Formal Agreement reflected the OCC's finding that the bank had accumulated deficiencies across multiple risk domains simultaneously: inadequate capital and strategic planning processes, failure to properly manage credit concentrations, weaknesses in credit underwriting and administration standards, and BSA/AML program deficiencies that constituted violations of the Bank Secrecy Act.

The multi-domain nature of the formal agreement — spanning credit risk, capital adequacy, and BSA compliance simultaneously — is characteristic of a community bank that has experienced deterioration across several risk areas at once, often associated with a change in business strategy, rapid growth, or deterioration in management oversight. The BSA component required remediation of the bank's AML compliance program to meet minimum regulatory standards.

Primary Source: OCC Enforcement Action Search — National Iron Bank Formal Agreement (July 2023)