The bank activities were illegal and non compliant. The OCC was about to cut them out of the entire banking network for poor reporting, meaning no OCC-licensed banks could take or send wires to them or hold accounts in their name. It would have shut off all trade for this bank without knowing what they’re doing or alleging any crime, yet.

This is how the US enforces its will worldwide.

The Treasury has a similar way to do that, without the OFAC list. They did it in 2018

https://www.google.com/amp/s/www.forbes.com/sites/francescop...

Back to the OCC, the outcome of the audit would have solidified criminal charges against the bank directors, but then they backed off with the “this is a government operation” excuse. Other reasons they would back off being any other kind of leverage, which small banks do not have.