June 21, 2025 – A shocking case of financial misconduct has rocked the banking industry, as the Office of the Comptroller of the Currency (OCC) has issued a lifetime industry ban against William Shane Garrow, a former senior vice president of private banking at a BOK Financial subsidiary in Tulsa, Oklahoma.
Garrow is accused of orchestrating a sophisticated scheme that siphoned approximately $3,437,536 from customer accounts over three years, between March 17, 2021, and March 12, 2024, for personal gain.
The allegations, detailed in a recent OCC enforcement action, have also led to federal criminal charges, sending ripples through the financial sector and raising questions about oversight in private banking.
According to the OCC, Garrow exploited his position to misappropriate funds from multiple customer accounts under the bank’s custody, acting without the knowledge or authorization of the affected clients.
The regulator’s findings reveal a pattern of deliberate misconduct, including the issuance of fraudulent cashier’s checks made payable to himself and unauthorized transfers to accounts he controlled at other financial institutions.
When clients noticed discrepancies, Garrow allegedly deflected scrutiny by claiming the issues were clerical errors that BOK Financial would resolve, further concealing his actions.
The OCC’s report states, “Garrow engaged in unsafe and unsound practices and violations of law that resulted in significant losses for the bank and its customers.”
The scale of the theft, combined with the extended duration of the scheme, has prompted a broader investigation into how such actions went undetected for years.
Federal Charges and Industry Ban
In addition to the OCC’s lifetime ban, which prohibits Garrow from working at any insured depository institution, including banks and credit unions, federal prosecutors have filed charges of bank fraud against him.
An affidavit cited by local outlet FOX23 alleges that Garrow’s embezzlement began as early as September 2012 and continued until April 2024, with losses totaling over $4.2 million across at least 16 customer accounts.
This discrepancy in reported figures suggests the possibility of additional victims or further financial damage yet to be fully uncovered.
BOK Financial, upon discovering the misconduct, conducted an internal investigation and cooperated fully with law enforcement.
A spokesperson for the bank stated, “Client impact was isolated and remediated upon discovery,” emphasizing that the institution has since strengthened its internal controls to prevent similar incidents.
The case has sparked renewed scrutiny of oversight mechanisms in private banking, where high-net-worth clients often entrust significant sums to individual bankers.
Experts suggest that the prolonged nature of Garrow’s alleged scheme highlights vulnerabilities in monitoring systems, particularly at institutions managing substantial custodial accounts.
“This incident underscores the need for robust checks and balances, including real-time transaction monitoring and mandatory third-party audits,” said Dr. Emily Carter, a financial regulation expert at the University of Oklahoma.
The scandal also comes at a time when the banking sector is grappling with rising incidents of fraud.
According to a recent report by the Federal Deposit Insurance Corporation (FDIC), insider fraud accounted for nearly 15% of financial institution losses in 2024, a trend that has prompted regulators to push for stricter compliance measures.
Customer Impact and Remediation Efforts
While BOK Financial has assured affected clients that their losses have been addressed, the emotional and financial toll on victims remains significant.
“Trust is the cornerstone of private banking,” said Carter.
“When that trust is violated, it can take years for clients to regain confidence in the system.”
The bank has not disclosed the exact number of affected customers but confirmed that remediation efforts are complete.
The Garrow case has reignited calls for regulatory reform to prevent insider fraud.
Proposals include mandatory rotation of private bankers to limit prolonged access to client accounts, enhanced whistleblower protections, and the adoption of AI-driven fraud detection systems.
The OCC has signaled its commitment to holding individuals accountable, with Comptroller Joseph Otting stating, “Our actions reinforce the expectation that bank employees must adhere to the highest standards of integrity.”
As the legal proceedings against Garrow unfold, the banking industry faces a critical moment to reassess its safeguards and restore public confidence.
The case serves as a stark reminder that even trusted insiders can exploit vulnerabilities, leaving regulators, banks, and customers to grapple with the fallout.
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