The Treasury Department’s Office of the Comptroller of the Currency (OCC) cited three banks for unsafe and unsound business practices that mirror issues similar to what spurred last year’s banking crisis, including risks posed to bank investments by higher interest rates and liquidity concerns in the event of a bank’s failure.

In a press release issued Thursday, the OCC announced it entered into a formal agreement with First FS & LA for the bank’s “failure to develop and implement an appropriate strategic plan, appropriately manage and control liquidity and interest rate risks, implement effective Bank Secrecy Act/anti-money laundering (BSA/AML) internal controls,” and failing to appoint a BSA officer with sufficient expertise.

In addition to addressing those risks, First FS & LA, a community bank based in Ohio, was ordered by the OCC to hire a BSA officer “vested with sufficient independence, authority, and resources to fulfill the duties and responsibilities of the position and ensure compliance with the requirements of the BSA and its implementing regulations.”

Minnesota-based Heritage Bank—an employee-owned, digital-first bank with $590 million in total assets–agreed to a cease-and-desist order related to “capital adequacy, capital and strategic planning, credit review, ongoing monitoring of the credit portfolio, liquidity and liquidity management practices, and the allowance methodology.”

Heritage Bank was ordered to implement a strategic plan to improve its identification, measurement, monitoring, and control of its liquidity risk exposure, including during stress events.

In a formal agreement with Minnstar Bank, the OCC homed in on issues related to concentrations of credit in the bank’s lending portfolio. Minnstar, also of Minnesota, will be required to develop limits on certain types of lending and to create a plan to reduce its credit concentration.

Both liquidity and concentration in certain industries were issues that led to the demise of three mid-sized banks last year: Silicon Valley Bank, First Republic Bank, and Signature Bank. In a June 2023 semiannual risk assessment, the OCC warned banks not to be complacent regarding risk management.

First FS & LA, Heritage, and Minnstar did not respond to requests for comment.