The OCC issued a consent order against Blue Ridge Bank, N.A. on January 24, 2024, designating the bank as being in "troubled condition" due to its failed banking-as-a-service fintech partnerships, with violations of BSA/AML program requirements, unsafe practices in capital and liquidity management, and a prohibition on new fintech relationships without prior OCC approval.

Blue Ridge Bank, N.A. — OCC "Troubled Condition" BaaS Consent Order (2024)

Outcome: The OCC issued a consent order against Blue Ridge Bank, N.A. of Martinsville, Virginia on January 24, 2024, designating it as being in "troubled condition" — the most severe OCC safety-and-soundness designation short of receivership — due to systemic failures in BSA/AML compliance and risk management arising from its banking-as-a-service fintech partnerships, with no civil money penalty but extensive operational restrictions.

Blue Ridge Bank, N.A. had aggressively built a banking-as-a-service business to serve fintech companies, taking on dozens of fintech partnerships that provided revenue growth but outpaced the bank's compliance infrastructure. In 2022, the OCC issued an initial written agreement requiring Blue Ridge to bolster its AML program and improve oversight of fintech partners. When Blue Ridge failed to meet the OCC's requirements under that agreement, the OCC converted it into a formal consent order in January 2024 — a significant escalation reflecting the regulator's judgment that the bank had not achieved sustainable compliance.

The January 2024 consent order found that Blue Ridge had failed to establish and maintain a reasonably designed BSA/AML program, with systemic internal controls breakdowns, weak independent testing of AML processes, and insufficient BSA compliance staffing — all traced to risk management challenges created by the bank's extensive third-party fintech relationships. Beyond BSA, the order addressed deficiencies in capital and strategic planning, liquidity risk management, and information technology controls. The OCC's designation of Blue Ridge as being in "troubled condition" reflected the severity of the overall safety-and-soundness concerns.

The consent order imposed immediate operational restrictions: Blue Ridge was prohibited from establishing any new third-party fintech relationships or materially expanding existing ones without prior OCC permission. The bank was required to maintain a leverage ratio of 10% and a total capital ratio of 13% — significantly higher than the well-capitalized minimum standards of 5% and 10% — to provide a capital buffer during remediation. The OCC terminated the consent order in November 2025 after Blue Ridge successfully completed the required remediation.

Primary Source: OCC Consent Order — Blue Ridge Bank, N.A. (2023-68, effective January 2024)