News & Analysis as of

BSA/AML Board of Directors

Carlton Fields

Expect Focus - Volume I, January 2025

Carlton Fields on

The Mysterious Boundary Beyond Which “Personal” Relationships Jeopardize a Director’s Independence - In a recent enforcement action, the SEC concluded that the relationship between James Craigie and an officer of Church &...more

Thomas Fox - Compliance Evangelist

TD Bank, Part 7-Caremark Claims-Officers

Next, I explore the TD Bank AML/BSA enforcement action by looking at the expansion of the Caremark Doctrine. In the McDonald’s case, the Delaware Court of Chancery took the Caremark Doctrine further by applying the Duty of...more

Thomas Fox - Compliance Evangelist

TD Bank, Part 6 – Caremark Claims – The Board of Directors

Today, I continue my exploration of the TD Bank AML/BSA enforcement action through two of the most significant cases regarding Boards of Directors and corporate compliance: the Caremark and Stone v. Ritter decisions. The...more

Ballard Spahr LLP

OCC Action Highlights Increased Accountability Facing Boards Of Directors

Ballard Spahr LLP on

Regulatory Examination and Related Enforcement Also Highlights Perceived Risks of Banking Crypto Clients - The Department of the Treasury’s Office of the Comptroller of the Currency (“OCC”) recently issued a Consent Order...more

Carlton Fields

Yellow Flags Are Not Red Flags: Delaware Court of Chancery Rejects Caremark Claim in Reiter v. Fairbank

Carlton Fields on

In October 2016, the Delaware Court of Chancery rejected a shareholder derivative lawsuit premised on an alleged lack of oversight by the directors of Capital One Financial Corp., Reiter v. Fairbank, C.A. No. 11693-CB, 2016...more

The Volkov Law Group

Ten Key Elements of an AML Compliance Program

The Volkov Law Group on

AML compliance reminds me of a classic Three Stooges scene from A Plumbing We Will Go – Curly, as one of the plumbers, continues to add pipes to a leaking bathtub, only to be surprised when the water continues to come out of...more

The Volkov Law Group

Commerzbank’s Compliance Catastrophe — Flouting Sanctions and BSA/AML Laws (Part II of III)

The Volkov Law Group on

Sometimes a picture is very clear but legal words and concepts are proffered in an attempt to disguise and even deceive. As set forth in the factual statements outlined by the government, and agreed to by Commerzbank, it is...more

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