OCC Identifies Operational Risk Deficiencies in MUFG Union Bank
The Office of the Comptroller of the Currency (OCC) issued a Cease and Desist Order against MUFG Union Bank for deficiencies in technology and operational risk governance. The MUFG Union Bank is based in the United States and is owned by the Japanese banking entity Mitsubishi UFJ Financial Group. This action was the result of the bank's unsafe or unsound practices in this area and for the bank’s non-compliance with the interagency guidelines establishing information security standards. The Order requires the bank to improve longstanding technology and operational risk governance, technology risk assessments, internal controls, and staffing deficiencies to address the unsafe or unsound practices.
Within 90 days of the effective date of this Order, the bank shall develop an acceptable, written action plan detailing the remedial actions necessary to achieve compliance with Articles V through XI of this Order, thereby addressing the unsafe or unsound practices and noncompliance. The bank shall submit the action plan to the Examiner-in-Charge for review and prior written determination of no supervisory objection. The action plan, at a minimum, shall specify a description of the corrective actions needed to achieve compliance with each Article of this Order, reasonable and well-supported timelines for completion of the corrective actions required by this Order, and the person(s) responsible for completion of the corrective actions required by this Order. The Board shall ensure that the bank has timely adopted and implemented all corrective actions required by this Order. The Board shall also verify that the bank adheres to the corrective actions and that these actions are effective in addressing the identified deficiencies. In each instance in which this Order imposes responsibilities upon the Board, it is intended to mean that the Board shall:
- authorize, direct, and adopt corrective actions on behalf of the bank, as may be necessary to perform the obligations and undertakings imposed on the Board by this Order
- ensure the bank has sufficient processes, management, personnel, control systems, and corporate and risk governance to implement and adhere to all provisions of this Order
- require that bank management and personnel have sufficient training and authority to execute their duties and responsibilities pertaining to or resulting from this Order
- hold bank management and personnel accountable for executing their duties and responsibilities pertaining to or resulting from this Order
- require appropriate, adequate, and timely reporting to the Board by bank management of corrective actions directed by the Board to be taken under the terms of this Order
- address any noncompliance with corrective actions in a timely and appropriate manner
Related Links
Keywords: Americas, US, Banking, Operational Risk, Cease and Desist Order, Regtech, MUFG, Technology Risk, Compliance Risk, Governance, OCC
Featured Experts

Michael Denton, PhD, PE
Dr. Denton provides industry leadership in the quantification of sustainability issues, climate risk, trade credit and emerging lending risks. His deep foundations in market and credit risk provide critical perspectives on how climate/sustainability risks can be measured, communicated and used to drive commercial opportunities, policy, strategy, and compliance. He supports corporate clients and financial institutions in leveraging Moody’s tools and capabilities to improve decision-making and compliance capabilities, with particular focus on the energy, agriculture and physical commodities industries.
Related Articles
EBA Clarifies Use of COVID-19-Impacted Data for IRB Credit Risk Models
The European Banking Authority (EBA) published four draft principles to support supervisory efforts in assessing the representativeness of COVID-19-impacted data for banks using the internal ratings based (IRB) credit risk models.
BIS Hub Updates Work Program for 2022, Announces New Projects
The Bank for International Settlements (BIS) Innovation Hub updated its work program, announcing a set of projects across various centers.
US Senate Members Seek Details on SEC Proposed Climate Disclosure Rule
Certain members of the U.S. Senate Committee on Banking, Housing, and Urban Affairs issued a letter to the Securities and Exchange Commission (SEC)
EIOPA Consults on Review of Securitization Framework in Solvency II
The European Insurance and Occupational Pensions Authority (EIOPA) published a consultation paper on the advice on the review of the securitization prudential framework in Solvency II.
UK Authorities Issue Regulatory and Reporting Updates for Banks
The Prudential Regulation Authority (PRA) issued a statement on PRA buffer adjustment while the Bank of England (BoE) published a notice on the statistical reporting requirements for banks.
BaFin Consults on Resolvability Requirements for Resolution Planning
The Federal Financial Supervisory Authority of Germany (BaFin) proposed to amend the “Capital Investment Conduct And Organization Ordinance” and issued a draft circular on the minimum resolvability requirements for resolution planning.
EBA Consults on Certain Standards and Guidelines Under CRR and BRRD
The European Banking Authority (EBA) proposed guidelines, for the resolution authorities, on the publication of the write-down and conversion and bail-in exchange mechanic, with the comment period ending on September 07, 2022.
OJK Publishes Regulatory Updates for Financial Sector Entities
The Financial Services Authority of Indonesia (OJK) is strengthening cooperation with the Australian Prudential Regulation Authority (APRA) and the Japanese Financial Services Agency (JFSA)
EU Publishes Rules on DLT and Data Governance
The European Parliament and the Council published Regulation 2022/868 on European data governance (Data Governance Act).
EBA Publishes Phase 2 of Reporting Framework 3.2
The European Banking Authority (EBA) published phase 2 of its reporting framework 3.2. The technical package supports the implementation of the updated reporting framework by providing standard specifications