A deep dive into the consent order issued last week by the Office of the Comptroller of the Currency (OCC) against USAA Federal Savings Bank imparts lessons for compliance officers in the financial services industry on how—and how not—to maintain a Bank Secrecy Act/anti-money laundering (BSA/AML) compliance program.

Jaclyn Jaeger is a freelance contributor to Compliance Week after working for the company for 15 years. She writes on a wide variety of topics, including ethics and compliance, risk management, legal,...