If your bank just signed a consent order with a federal banking regulator, the next 90 days will define the next two years of your compliance program. The order itself begins a structured remediation phase that often runs for years. Boards that move with discipline, transparency, and proportional investment in BSA/AML capability come through it stronger. Boards that treat it as a project to close out tend to wind up in second orders.
Use this as a practical guide for what to do in the first 30, 60, and 90 days, what regulators look for in a credible remediation, and how to handle the relationships (with fintech partners, examiners, and your own staff) that will be tested along the way.
The recent OCC consent order against Community Federal Savings Bank (CFSB), entered in April 2026 and published in May (Docket No. AA-ENF-2025-21), is the current public example for BaaS and sponsor-bank programs. The order cites deficiencies in the bank’s Bank Secrecy Act and anti-money laundering (BSA/AML) compliance program, with violations of 12 CFR 21.21, 12 CFR 163.180(d), and 31 CFR 1010.520(b)(3), and requires the bank to appoint a compliance committee and submit a written remedial action plan acceptable to the OCC. The pattern in that order (growth outpacing controls, automated suspicious activity triage that closed too many alerts, weak customer due diligence on certain payment processing customers, under-resourced BSA/AML staffing and independent testing) repeats across recent BSA/AML enforcement actions and is a useful frame for any bank in this position.
What a consent order actually obligates your bank to do
A consent order is a public, binding agreement between the bank and its primary federal regulator. It is signed by the board, filed publicly, and carries specific deliverables tied to deadlines.
For BSA/AML orders, the core obligations typically include:
- Standing up a compliance committee, often comprising independent directors, with a defined charter, meeting cadence, and reporting requirements.
- Submitting a written remedial action plan for the regulator’s review and acceptance, covering each cited deficiency.
- Establishing periodic progress reports to the regulator (often quarterly) with documented evidence of milestones.
- Engaging or strengthening independent testing.
- In some cases, retaining a third-party consultant to assist with remediation or validation.
The clock starts at execution. Failure to submit an acceptable plan on time, or to meet committed milestones, escalates the matter and can trigger civil money penalties or individual actions against responsible parties.
The first 30 days: stabilize, stand up, communicate
The early days are about establishing structure and avoiding self-inflicted damage.
Stand up the compliance committee immediately
If the order requires a compliance committee, charter it within days. Identify the independent directors, define the scope, set the first three meeting dates, and document everything. Regulators read minutes.
Open and structure your regulator interface
Designate a senior point of contact for the regulator, usually the chief compliance officer (CCO) or BSA officer, supported by general counsel. Establish a written log of every regulator communication, request, and response. Decide in advance who can speak to the regulator and on what topics.
Communicate internally before the rumors do
Brief executive leadership, the board, and key business units on what the order says, what it does not say, and the expected workplan. A short, factual internal memo paired with a leadership talking-points document is worth more than weeks of after-the-fact clarification. Deposits are safe. Programs are not shutting down. The bank has agreed with the regulator on a remediation path.
Notify partners on a deliberate timeline
For sponsor banks with fintech partners, partner managers need a coordinated message: what the order says (the public facts), what you are doing about it, and what you will be asking partners to do. Send it before partners read it on a press wire or social.
Days 30 to 60: build a credible remedial action plan
The remedial action plan is the document the regulator will judge you on. Acceptable plans share a few qualities:
- They diagnose root cause, not symptoms. A plan that says “we will increase staffing” without explaining why staffing was insufficient and how the new structure prevents recurrence will come back with revisions.
- They are concrete and time-bound. Each deficiency cited in the order should have an owner, milestones, deliverables, and a completion date.
- They are sustainable. Regulators are skeptical of plans that depend on heroic effort or one-time spending. The plan should describe the steady-state operating model after remediation.
- They cover governance, not just operations. Board oversight, management reporting, second-line independence, and third-line testing all need explicit attention.
- They are honest about dependencies. Customer due diligence (CDD) cannot be fixed without coordinated effort across business lines, technology, and operations. Say so.
If your bank does not have the in-house bandwidth to draft an acceptable plan, bring in BSA/AML remediation support before submitting a first draft. A weak first draft costs months.
Days 60 to 90: execute, document, and reset partner expectations
Once the plan is submitted (and as you await acceptance), execution begins. Three areas usually need the most attention.
Suspicious activity monitoring and CDD
Most BSA/AML consent orders cite some combination of weak transaction monitoring, automated triage closing too many alerts, and under-investigated CDD on higher-risk customers. Plan to tune rules, re-baseline alert disposition standards, add documented quality assurance on closures, and re-paper enhanced due diligence (EDD) for higher-risk segments. Cross-border activity and foreign financial institutions warrant their own treatment under USA PATRIOT Act 314(a) information-sharing expectations.
Staffing, training, and independent testing
Right-size the BSA/AML function for the volume and complexity of your current portfolio. Make training role-specific. Make independent testing genuinely independent, with a scope and cadence calibrated to risk. Document the qualifications of every named role; regulators will ask.
The partner cascade
Sponsor banks satisfying a BSA/AML order must demonstrate that they understand every partner’s business, customers, and transaction flows. The partner cascade (refreshed risk assessments, evidence requests on KYC and CDD files, transaction monitoring scrutiny, contractual updates, and in some cases volume caps or offboarding) is part of the remediation, not separate from it. Handle it with the same documentation discipline as the rest of the plan. Programs that need to be offboarded should be offboarded with notice and a documented rationale.
What regulators reward over the next 12 to 24 months
Acceptance of the remedial action plan begins the period in which the regulator decides how to credit the bank for sustained, demonstrable improvement.
Banks that earn credit tend to:
- Report progress proactively, with evidence, before they are asked.
- Surface their own issues. Self-identified findings carry more weight than examiner-identified findings.
- Maintain stable, senior BSA/AML leadership through the remediation period.
- Treat the consent order as a program shift. Headcount, governance, and reporting changes persist after the order is lifted.
- Build a paper trail that an outside reviewer can follow from finding, to root cause, to plan, to evidence of completion, to ongoing monitoring.
Common pitfalls
A few patterns repeat across orders that escalate rather than resolve cleanly.
- Treating the order as a documentation problem. The work is in the controls and governance changes themselves; documentation is the evidence of that work.
- Concentrating remediation in one team without lasting governance changes around it.
- Under-investing in independent testing and second-line review, then arguing the program is healthy on first-line evidence alone.
- Botching partner communications through surprise offboardings, inconsistent asks, or long silences followed by panic requests.
- Letting senior BSA/AML leadership turn over mid-remediation. Continuity is one of the regulator’s most-watched quality signals.
How Equinox helps banks under consent orders
Our team has worked directly on consent order remediation for a large US banking institution. Equinox is a team of compliance, risk, and regulatory operators with deep experience inside banks, fintechs, and sponsor-bank programs. When a bank receives a BSA/AML consent order, we typically help in four ways:
- Independent reviews and remedial action plan support, drafting or pressure-testing the plan before submission so the first version the regulator sees is the strongest one.
- BSA/AML program remediation, including governance, transaction monitoring tuning, CDD and EDD refresh, and partner risk frameworks for sponsor banks.
- **Fractional BSA/AML Officer and fractional CCO support** to lead remediation or backfill senior compliance leadership during the engagement.
- Independent testing and audit readiness so the bank can demonstrate sustained effectiveness to its regulator and its board.
If your bank is preparing for, responding to, or rebuilding from a consent order, book a consultation with Equinox.
📌 This article is general information and not legal advice. For obligations specific to your bank, consult qualified counsel.
