Consent Order & MRA Remediation
Independent validation testing, root cause analysis, and regulator-ready closure packages for institutions under FDIC, OCC, or Federal Reserve enforcement action.
Credible Remediation, Sustainable Closure
Receiving a consent order is one of the most consequential events in an institution's history. The path out requires more than a project plan. It requires credibility with your regulators, root-cause discipline, and validation that stands up to 3rd-line scrutiny.
Our principal has led remediation across multiple enforcement actions, including multi-year programs for Top 10 U.S. banks. We build programs regulators trust.
- Independent 3rd-line validation testing
- Risk-based test script design and execution
- Root cause analysis tied to sustainable controls
- Closure package development and regulator liaison
- Board reporting and governance advisory
- Embedded leadership for multi-year programs
Regulator-facing experience: direct engagement with FinCEN, state banking departments, FDIC and OCC exam teams and the DOJ, plus Big Four and national-firm validation work.
The Moments That Bring Institutions to Us
Most remediation work starts with a specific trigger. If one of these sounds like your week, start there.
A New Consent Order
The order has been signed, the first deadlines are running, and the board needs a credible plan and a team to carry it.
MRAs That Keep Coming Back
Findings are open past their target dates, or an issue reported as closed has resurfaced at the next exam.
Validation Before the Examiner Returns
Corrective actions are reported complete and need independent testing and evidence before anyone tells the regulator they are done.
A Stalled Remediation Office
Deadlines are slipping, workstreams report green, and nobody can produce the evidence. The program needs leadership to reset it.
A Board That Needs a Clear View
Directors carry obligations under the order and need reporting that shows real progress and real risk, not status colors.
A Sponsor Bank Under Order
Your fintech partner programs sit inside the scope of the order, and partner oversight has to be rebuilt and tested.
Fintech partner oversight for sponsor banksRoot Cause, Remediate, Validate, Close
Remediation that closes cleanly moves through four stages, and the evidence needed for the last stage is planned in the first.
- 01
Root Cause
Trace each article and finding to why it happened: ownership, control design, data, staffing or governance. Then look across the institution for the same weakness, not only where the examiner found it.
- 02
Remediate
Tie each corrective action to a sustainable control. Every action gets an owner, a deadline and the evidence it must produce, plus a named owner for the process once the remediation team stands down.
- 03
Validate
Test each action independently with risk-based scripts, confirming it addresses the finding and operates as intended before anyone reports it as complete.
- 04
Close
Build closure packages article by article, report progress to the board, and support your regulator conversations through the examiner's review.
Engagements We've Led
Anonymized engagements reflecting the scope and impact of our work.
Mid-Size Community Bank · Southeast
Led independent 3rd-line validation testing under FDIC consent order. Developed risk-based test scripts and executed validation across 20+ remediation initiatives spanning AML, GRC, and enterprise governance workstreams.
Top 10 U.S. Financial Institution
Directed BSA/AML testing and MRA validation across a multi-year remediation program. Managed quality assurance across the KYC customer file refresh program evaluating CDD/EDD standards.
Top 25 U.S. Banking Institution
Conducted comprehensive 2LOD compliance testing and transactional reviews across the Banking division. Identified deficiencies and recommended actionable remediation strategies.
Board and Committee Advisory Under Enforcement
A consent order does not only direct management. Orders typically place specific obligations on the board: approving plans and policies, overseeing progress against deadlines, and in many cases standing up a board committee that monitors and reports on compliance with the order. Directors generally need to show examiners that they understand the order and are challenging management, not only receiving updates.
We advise boards and their committees through the life of the order. Reporting tracks every article, corrective action and validation result in plain language. Briefings prepare directors for the questions examiners ask. Before any claim of completion goes to the regulator, we give a practitioner's read on whether the evidence supports it.
We support the board's oversight role. Management and your BSA Officer remain accountable for official correspondence with the regulator, and your counsel advises on legal questions.
Reading for Institutions Under Enforcement
Why consent order remediation programs fail, and the three decisions that prevent it
Governance, root-cause resolution and sustainability: the decisions that separate programs that close cleanly from programs that drag on.
Why consent order remediation programs failWhat the 2026 BSA/AML exam cycle is signaling to mid-size institutions
Supervisory priorities emerging from recent enforcement actions: BSA/AML leadership and resourcing, transaction monitoring and data controls, and sanctions and third-party risk oversight.
2026 BSA/AML exam cycle signalsCommon Questions
How quickly can you start after we receive a consent order?
Typically within 2 weeks for scoped engagements. For embedded leadership roles, we align to your regulator's deadlines and internal approval cycles.
What does independent validation involve?
Independent validation tests whether each corrective action in the order or MRA addresses the finding and is operating as intended. We start from the articles and findings, agree the validation approach and sampling with management, and write risk-based test scripts for each action. Testing reviews documentation, re-performs controls and samples transactions and customer files.
Every result is documented in workpapers with the evidence behind it, and exceptions go back to management before anything is reported as complete. Validation has to stay independent of the people who did the remediation work, so we settle that question when the engagement is scoped. Our independent BSA/AML review for banks and MSBs runs on the same testing discipline.
How do closure packages get built?
Article by article, from the start of the program, not assembled at the end. For each requirement, the package brings together what the order required, what management did, the evidence that the fix is in place, the validation testing and its results, and how any exceptions were resolved. It closes with a summary the board can review and approve before submission.
We develop the package and support the regulator conversation. Your management team and BSA Officer own the submission, and the decision to close the order rests with your regulator.
What do examiners look for in root cause analysis?
Examiners generally want to see that you understand why the problem happened, not only what went wrong. A credible root cause analysis goes past “human error” or “the procedure was not followed” to the underlying reason: unclear ownership, a control never designed for the risk, poor data feeding monitoring, thin staffing, or a governance gap that let issues age.
They typically look for a clear line from each root cause to a corrective action, evidence that the institution checked for the same weakness beyond where it was found, and sustainable controls rather than one-time cleanups.
Do you work directly with our regulator?
We support your regulatory relationship. Our principal has extensive experience as examiner liaison, but we never substitute for your BSA Officer or management team in official correspondence.
Can you serve banks outside North Carolina?
Yes. We serve banks and financial institutions nationwide. Our principal is based in Raleigh, NC, with engagements conducted both on-site and remotely.
How do you price consent order engagements?
Fixed-fee for scoped validation engagements; monthly retainer for embedded leadership; blended for multi-workstream remediation offices. Every engagement starts with a discovery call.
Is Ethixera a law firm?
No. Ethixera Advisory is a compliance advisory firm, not a law firm, and does not provide legal advice. We validate, test and help run remediation programs, and we work alongside your counsel on any question that calls for legal judgment.
Ready to Build a Credible Remediation Plan?
Let us discuss your enforcement action, assess the gaps, and scope the engagement.