The U.S. Comptroller of the Currency has issued a cease-and-desist order against the former general counsel of a Michigan bank that recently pleaded guilty to carrying out a $69 million fraud, even though the regulator is not asserting that the general counsel in any way participated in the wrongdoing.

This month’s little-noticed order against Colleen Kimmel, who served as general counsel of suburban Detroit-based Sterling Bancorp from 2016 until she resigned last year, should serve as a cautionary tale for bank legal and compliance leaders nationwide, Sam Finkelstein, an associate at the boutique compliance law firm Volkov Law Group, wrote in a Feb. 23 note to clients.