The ruling mandates that Anchorage appoint a bank secrecy officer to oversee the city's adherence to the Bank Secrecy Act, the cornerstone of AML and KYC systems in the United States. It also calls for forming a compliance committee with at least three members and a review of current high-risk clients.
In most cases, a consent order signifies that both parties — in this example, the OCC and Anchorage Digital — have agreed on the following measures. Anchorage "has started corrective action and is committed to taking all necessary and appropriate efforts to fix the inadequacies highlighted by the OCC," according to the ruling.
Since early January, Anchorage has operated under a conditional national bank charter issued by the OCC, which was issued under Brian Brooks, the acting comptroller of the currency at the time. Anchorage is operating under a probationary status due to the nature of its charter. The OCC has not issued any further such charters since Michael Hsu took over the post.