U.S. Bank National Association (USBNA) and its parent U.S. Bancorp have faced significant regulatory actions, primarily criminal and civil money penalties and one notable deferred prosecution agreement (DPA) for Bank Secrecy Act (BSA)/anti-money laundering (AML) failures. Pending full criminal convictions and uguilty pleas have resulted in recent years; the key case was resolved via deferral after the bank admitted facts and paid substantial penalties.
Major 2018 BSA/AML Violations (Most Significant Action)
- DOJ Criminal Charges (Deferred): In February 2018, the U.S. Attorney’s Office for the Southern District of New York charged U.S. Bancorp with two felony violations of the Bank Secrecy Act related to USBNA’s willful failures (2009–2014):
- Inadequate AML program (under-resourced, alert capping instead of proper investigation).
- Failure to file required suspicious activity reports (SARs).
- The bank “operated its AML program ‘on the cheap’” and concealed deficiencies from regulators.
- Deferred Prosecution Agreement (DPA): Charges deferred for 2 years upon admission of facts, $528 million penalty (via forfeiture and payments), and compliance reforms. The DPA was successfully completed, leading to dismissal. justice.gov
- Coordinated Penalties (Total ~$613 million):
- FinCEN: $185 million civil money penalty.
- OCC: $75 million.
- Federal Reserve: $15 million cease-and-desist order. fincen.gov
This remains the primary “criminal” regulatory matter; it exposed the bank to money laundering risks but did not lead to a conviction .Other Notable Regulatory Violations (Primarily Civil)
- 2023 Prepaid Card/Unemployment Benefits: OCC and CFPB each assessed $15 million penalties (plus redress) for unfair practices in handling frozen ReliaCard unemployment benefits during COVID-19 (deficient access/verification processes). The CFPB order was terminated in 2025 after compliance. occ.gov
- 2022 Unauthorized Accounts: CFPB fined USBNA $37.5 million for opening credit cards, lines of credit, and deposit accounts without consent, plus improper use of consumer reports. Order terminated in 2025. consumerfinance.gov
- 2017 Bankruptcy Filing Violations: OCC $15 million penalty for non-compliant proofs of claim ( POC ) and notices in bankruptcy cases (2009–2014). occ.treas.gov
- Additional historical actions include other consumer/compliance fines, but nothing approaching the scale of the 2018 AML case.
U.S. Bank Trust Company, N.A. This is a national trust company subsidiary focused on fiduciary, corporate trust, and trustee services (e.g., in mortgage securitizations/foreclosures). It has many prominent criminal and major regulatory violations in public records. Issues in foreclosure litigation are typically civil disputes over standing or procedures, as well as bank misconduct. It falls under the same U.S. Bancorp oversight, so parent-level AML/consent orders indirectly apply, and some entity-specific enforcements stand out.
Summary and Context
- Criminal Exposure: Limited to the 2018 DPA (resolved without conviction). Banks rarely face full prosecutions due to systemic importance; regulators favor large fines + reforms.
- Violation Tracker Totals (approximate, via public databases): Hundreds of millions across AML, consumer, and banking violations since the 2010s, but dominated by the 2018 case. violationtracker.goodjobsfirst.org
- Major new criminal and outsized penalties being reported through 2025–early 2026.
For official details, review sources like OCC, CFPB, FinCEN, FBI, or DOJ announcements. If this relates to a specific incident, account, or legal matter, provide more details for targeted research. Suspected violations should be reported to regulators or law enforcement.