JPMorgan Chase fined $348.2m by the OCC and Federal Reserve over gaps in its trade surveillance (2024)

What happened?

JPMorgan disclosed in November 2023 that it was cooperating with investigations into whether it had provided comprehensive trading and order data to its surveillance, and in February 2024 that certain trading and order data from its Corporate and Investment Bank was not correctly feeding into its trade surveillance platforms. It said it expected to pay about $350 million to two regulators and was in advanced talks with a third.[7][8]

In its consent order the OCC found, and the bank neither admitted nor denied, that since at least 2019 the bank's trade surveillance program "has operated with gaps in venue coverage and without adequate data controls required to maintain an effective program," including "the Bank's failure to surveil billions of instances of trading activity on at least 30 global trading venues". It found a pattern of unsafe or unsound practices and assessed a $250 million civil money penalty.[1][2]

The Federal Reserve found that from 2014 through 2023 the firm "failed at various points in time to adequately surveil certain trading and order activity" in its Corporate and Investment Bank on at least 30 venues, and that the program operated "without adequate data oversight and reconciliation processes". Its order assessed $98,167,980 and required an independent review covering, among other things, "effective automated data reconciliation processes, and effective compensating controls where automation is unavailable".[4][5]

A separate OCC cease-and-desist order required the bank to strengthen trading-venue and data governance, including "effective automated reconcilements of venue order and trade data", to conduct a lookback to find where data deficiencies prevented surveillance, and to seek the OCC's non-objection before onboarding new trading venues.[1][3]

When did it happen?

1. Nov 2023

   JPMorgan discloses that it is cooperating with investigations into the completeness of trading and order data provided to its surveillance.[8]

2. Feb 2024

   JPMorgan discloses that some CIB trading and order data was not correctly feeding its trade surveillance platforms and that it expects to pay about $350 million.[7][8]

3. Mar 14, 2024

   The OCC assesses a $250 million penalty and issues a cease-and-desist order; the Federal Reserve assesses $98.2 million and issues its own order.[1][2][4][5]

4. Mar 30, 2026

   The OCC terminates its March 2024 cease-and-desist order against JPMorgan Chase Bank.[6][9]

What was the impact?

• Financial: $348.2 million in civil money penalties ($250,000,000 OCC; $98,167,980 Federal Reserve) · ≈ $348.2 million[1][4][5][8]
• Other: Billions of instances of trading activity on at least 30 global trading venues went unsurveilled at various points between 2014 and 2023; JPMorgan said its review found no employee misconduct or harm to clients or the market.[1][4][5][8]

Severity 4 of 5: Consent orders with $348.2 million in civil money penalties ($250 million OCC, $98.2 million Federal Reserve) for surveillance gaps covering billions of instances of trading activity on at least 30 venues between 2014 and 2023; no client or market harm was identified.

How did JPMorgan Chase respond?

A JPMorgan spokesperson said: "As we disclosed last month, we self-identified the issue, significant remedial actions have been taken and others are underway. We have not found any employee misconduct or harm to clients or the market in our review of the previously uncaptured data." The bank said it did not expect any disruption to client services. In its February 2024 filing it said it had completed enhancements to the CIB's venue inventory and data completeness controls.[7][8]

What was the outcome, and did regulators act?

JPMorgan paid both penalties and consented to the orders, which required corrective action, independent reviews of the trade surveillance program and regulator non-objection before onboarding new trading venues. On 30 March 2026 the OCC terminated its cease-and-desist order, saying the bank's safety and soundness no longer required it; Banking Dive reported no indication then that the Federal Reserve's companion order had been lifted.[3][5][6][9]

• OCC Consent Order + Civil Money Penalty against JPMorgan Chase Bank, N.A. (Mar 14, 2024, penalty $250 million)
• OCC Consent Order against JPMorgan Chase Bank, N.A. (Mar 14, 2024)
• Federal Reserve Cease and Desist Order + Civil Money Penalty against JPMorgan Chase & Co. (Mar 8, 2024, penalty $98.2 million)

1. OCC Assesses $250 Million Civil Money Penalty Against JPMorgan Chase Bank, N.A. Related to Bank's Trade Surveillance Program (NR 2024-25) official
   Office of the Comptroller of the Currency · Mar 14, 2024
   “The OCC found that JPMC failed to surveil billions of instances of trading activity on at least 30 global trading venues. These gaps and deficiencies in JPMC's trade surveillance program constitute unsafe or unsound banking practices.”
2. Consent Order for a Civil Money Penalty, AA-EC-2023-49 (JPMorgan Chase Bank, N.A.) official
   Office of the Comptroller of the Currency · Mar 14, 2024
   “In addition, the Bank's trade surveillance program has operated with gaps in venue coverage and without adequate data controls required to maintain an effective program.”
3. Consent Order, AA-EC-2023-50 (JPMorgan Chase Bank, N.A.) official
   Office of the Comptroller of the Currency · Mar 14, 2024
   “effective automated reconcilements of venue order and trade data”
4. Federal Reserve Board issues enforcement action against JPMorgan Chase & Co. and fines the firm approximately $98.2 million for an inadequate program to monitor firm and client trading activities for market misconduct official
   Board of Governors of the Federal Reserve System · Mar 14, 2024
   “The penalties announced by the Board and the Office of the Comptroller of the Currency total approximately $348.2 million.”
5. Order to Cease and Desist and Order of Assessment of a Civil Money Penalty, Docket Nos. 24-007-B-HC and 24-007-CMP-HC (JPMorgan Chase & Co.) official
   Board of Governors of the Federal Reserve System · Mar 14, 2024
   “from 2014 through 2023 (the "Relevant Period"), JPMC failed at various points in time to adequately surveil certain trading and order activity throughout the Firm's Corporate and Investment Bank ("CIB") on at least 30 global trading venues”
6. Order Terminating the Consent Order, AA-ENF-2026-17 (JPMorgan Chase Bank, N.A.) official
   Office of the Comptroller of the Currency · Mar 30, 2026
   “the OCC 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.”
7. JPMorgan fined nearly $350 million for inadequate trade reporting news
   Reuters · Mar 14, 2024
   “A bank spokesperson said the firm self-identified the issue and is working to address the matter, and does not expect any disruption of existing client services.”
8. JPMorgan Chase fined $348.2M over gaps in trade data reporting news
   Banking Dive · Mar 14, 2024
   “JPMorgan disclosed last month that certain trading and order data from JPMorgan's corporate and investment bank division was not correctly feeding into its trade surveillance platforms as required.”
9. JPMorgan order that drew $348.2M penalty ends news
   Banking Dive · Apr 17, 2026
   “There was no indication Friday that the companion Fed order against JPMorgan had been terminated.”