• OCC has terminated enforcement order against JPMorgan after remediation
• Original action cited major gaps in trade surveillance across global venues
• Bank paid nearly $350 million in combined penalties to regulators
• Improvements made to data controls and monitoring systems
• Federal Reserve order remains in place at this stage 

US regulators have lifted a major enforcement order against JPMorgan Chase, bringing an end to a high-profile crackdown on the bank’s trade surveillance controls that had resulted in nearly $350 million in penalties.

The decision by the Office of the Comptroller of the Currency marks a significant shift in the regulatory stance toward one of the world’s largest financial institutions, following what authorities now appear to consider sufficient remediation of earlier deficiencies.

The enforcement action, originally issued in March 2024, alleged that JPMorgan had failed to properly monitor client trading activity across a wide range of markets for nearly a decade.

At the time, regulators said the bank had operated with “gaps in trading venue coverage” and lacked the necessary data controls to support an effective surveillance program.

According to the OCC’s findings, the bank had failed to oversee billions of trading instances across at least 30 global venues, raising concerns about potential market misconduct and exposing weaknesses in internal systems.

Regulators described the deficiencies as “unsafe or unsound banking practices,” underscoring the seriousness of the issue.

The enforcement order required JPMorgan to undertake extensive corrective measures, including strengthening its surveillance systems, improving data completeness, and obtaining regulatory approval before onboarding new trading venues.

The bank was also instructed to engage an independent third party to review its surveillance framework.

In a new order signed on March 30 and made public this week, the OCC said it “believes that the safety and soundness of the Bank and its compliance with laws and regulations does not require the continued existence of the Order.” The regulator did not provide detailed reasoning for the decision.

The move suggests that JPMorgan has made sufficient progress in addressing the concerns raised by supervisors.

In earlier disclosures, the bank acknowledged that some trading and order data had not been properly integrated into its surveillance systems, particularly within its corporate and investment bank division.

“The Firm has completed enhancements to the CIB’s venue inventory and data completeness controls,” JPMorgan said in a February 2024 filing, adding that a review of previously unsupervised data was nearly complete and had not identified employee misconduct or harm to clients or markets.

The enforcement action formed part of a broader regulatory response that also included a parallel order from the Federal Reserve. While the OCC has now lifted its order, there has been no indication that the Fed has taken similar action.

The penalties associated with the case were substantial. JPMorgan agreed to pay $250 million to the OCC and an additional $98.2 million to the Federal Reserve, reflecting the scale of the deficiencies identified and the importance regulators place on robust market surveillance.

The case highlights the growing complexity of monitoring trading activity across fragmented global markets.

As banks expand their operations and connect to multiple venues, ensuring complete and accurate data capture has become a critical challenge.

For regulators, the episode underlines the importance of effective surveillance in maintaining market integrity.

For banks, it serves as a reminder that weaknesses in data infrastructure and control frameworks can carry significant financial and reputational costs.

The lifting of the OCC order may signal a more pragmatic approach to enforcement, where remediation efforts are recognized and formal oversight is withdrawn once regulators are satisfied with progress.

However, the absence of detailed explanation leaves open questions about how supervisory priorities may evolve.

For JPMorgan, the decision removes a key regulatory constraint and may allow greater flexibility in its trading operations.

More broadly, it reflects a moment of transition in regulatory oversight, where the focus is increasingly on outcomes rather than prolonged enforcement measures.