A September 24, 2025 U.S. District Court for the District of Columbia opinion in the case of Radtke v. U.S. Bureau of Customs & Border Protection casts further light on the U.S. Customs and Border Protection ruling process relating to the Jones Act. 

In this alert, Winston’s Financial Services Industry Group examines recent developments in debanking, focusing on two new OCC bulletins that clarify regulatory expectations. While these bulletins provide new insight into how the OCC is addressing debanking under the current administration, they also leave several important questions unanswered.

The OCC’s first bulletin addresses how politicized or unlawful debanking will factor into licensing applications and Community Reinvestment Act evaluations, emphasizing the importance of fair access and treatment. The second bulletin reminds banks of their obligations under the Right to Financial Privacy Act, particularly in light of recent congressional scrutiny, and underscores the need to protect customer financial records unless disclosure is legally required.

What does this mean for you?