Clear Fork Bank, N.A.
Outcome
The OCC issued a Cease and Desist Order against Clear Fork Bank, N.A. of Albany, Texas on October 8, 2024 for BSA/AML violations that the bank had failed to correct since 2021, including inadequate suspicious activity monitoring for its third-party payment processor portfolio — the bank being one of the oldest privately-owned banks in Texas with $800 million in assets and only six locations.
Details
Clear Fork Bank, N.A. — OCC BSA/AML Cease and Desist: Three Years of Repeat Violations (2024)
Outcome: The OCC issued a Cease and Desist Order against Clear Fork Bank, N.A. of Albany, Texas on October 8, 2024 (Docket AA-ENF-2024-82) for BSA/AML violations that the bank had failed to correct since they were first identified and addressed in a February 2021 OCC Formal Agreement — a three-year enforcement escalation demonstrating that small community banks face the same BSA compliance obligations as large institutions.
Clear Fork Bank, N.A. is one of the oldest privately-owned banks in Texas, headquartered in Albany, with approximately $800 million in assets and only six retail locations. Despite its small size and traditional community banking profile, the OCC's October 2024 Cease and Desist Order reflected persistent BSA/AML compliance deficiencies that the bank had failed to remediate across an approximately three-year period.
The OCC had previously issued a Formal Agreement to Clear Fork Bank on February 16, 2021, identifying BSA/AML program deficiencies. The bank failed to implement sufficient corrections throughout 2022 and 2023, continuing to operate without a BSA/AML compliance program adequate to assure and monitor compliance with legal requirements. The October 2024 Cease and Desist Order superseded and terminated the 2021 Formal Agreement while imposing stricter requirements.
The bank's board was ordered to revise its BSA/AML policies and procedures and ensure adherence, including implementing all corrective actions originally flagged in 2021. Notably, the order required the bank to develop processes for evaluating BSA/AML compliance risks posed by new business lines, products, or altered services — reflecting that Clear Fork's third-party payment processor portfolio had generated suspicious activity monitoring deficiencies that had not been adequately addressed. Within 45 days, the bank was required to submit a SAR lookback plan covering October 2022 through January 2024, examining activity from its third-party payment processor relationships.
Primary Source: OCC November 2024 Enforcement Actions Press Release — Clear Fork Bank
How Crucible Prevents This
Crucible's session-init gate would surface the February 2021 OCC Formal Agreement at every compliance session start, preventing three years of noncompliance. The instinct-observer would detect the recurring SAR monitoring gap pattern in the third-party payment processor portfolio. The quality-gate would block any new payment processor relationship without documented BSA/AML risk assessment and board approval.
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