News & Analysis as of

Compliance Enforcement Actions Bank Secrecy Act

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Buchalter

FinCEN Lowers Reporting Threshold for MSBs Near U.S.-Mexico Border to Combat Money Laundering

Buchalter on

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) operating within 30 specified ZIP codes near the U.S.-Mexico border...more

Bradley Arant Boult Cummings LLP

Kansas Bank's Suit Could Upend FDIC Enforcement Authority

On Nov. 19, 2024, the Federal Deposit Insurance Corp. issued a notice of assessment finding that between December 2018 and August 2020, CBW Bank — a single-branch bank in Weir, Kansas — failed to maintain an adequate...more

Sheppard Mullin Richter & Hampton LLP

FDIC Enforcement Spotlights Deficiencies in Kansas Bank’s Anti-Money Laundering Program

On December 27, 2024, the Federal Deposit Insurance Corporation (FDIC) announced a notice of assessment of a civil money penalty against a Kansas-based bank. The action, originally brought in November, imposed a $20.4 million...more

Lowenstein Sandler LLP

SEC’s 2025 Examination Priorities for Investment Advisers

Lowenstein Sandler LLP on

On October 21, 2024, the U.S. Securities and Exchange Commission (SEC) Division of Examinations (the Division) released its annual Examination Priorities for fiscal year 2025 (the Report). The Report identifies certain...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 5- The Reckoning

Today, I want to review the OCC Consent Order to see the bank’s requirements. This is separate from the DOJ requirements under the Bank’s Plea Agreement(s) and the FinCEN Consent. Further, the DOJ and OCC have mandated...more

The Volkov Law Group

TD Bank’s $3 Billion Settlement: A Review of Regulatory Settlements  (Part III of IV)

The Volkov Law Group on

TD Bank’s $3 billion settlement included coordinated regulatory settlements with the Federal Reserve Board (“Federal Reserve”), The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), and the...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 3 – Lessons Learned for Compliance

We continue our exploration of the resolution of the AML/BSA enforcement action involving the TD Bank US (the Bank) wholly owned by the TD Bank Group, a publicly traded (NYSE: TD) international banking and financial services...more

The Volkov Law Group

TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations (Part I of IV)

The Volkov Law Group on

In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 1-Money Laundering and the China Syndrome

Last week, representatives of the US government announced one of the largest sets of fines and penalties for failures in anti-money laundering ever laid down. It involved TD Bank N.A. and TD Bank US Holding Company. It was...more

The Volkov Law Group

Sterling Bank’s ex-General Counsel hit with OCC Cease-and-Desist over Longstanding BSA/AML Shortcomings

The Volkov Law Group on

The Treasury Department’s Office of the Comptroller of the Currency (“OCC”) has taken action against the former General Counsel of Michigan-based Sterling Bank and Trust in the agency’s latest action against an individual...more

Harris Beach Murtha PLLC

[Webinar] Third Party Risk is Your Risk - January 24th, 11:00 am - 12:00 pm EST

• Highlights of recent joint agency guidance on Third-Party Risk Management (3PRM) • How 3PRM considerations have increased in importance in BSA/AML compliance programs and enforcement actions • Lessons learned from...more

BakerHostetler

US Crypto Exchange Consents to $100M DFS Settlement for AML Compliance Failures

BakerHostetler on

On January 4, 2023, the New York State Department of Financial Services (“DFS”) announced that Coinbase, Inc., a major U.S. cryptocurrency exchange, will pay a $50 million penalty and invest an additional $50 million in its...more

BakerHostetler

Major U.S. Crypto Exchange Consents to $29 Million Penalty for Historic BSA and OFAC Violations

BakerHostetler on

​​​​​​​On October 11, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced a $29 million civil monetary penalty against Bittrex, a...more

Harris Beach Murtha PLLC

Recent Enforcement Actions Indicate Heightened Scrutiny of BSA/AML Compliance and Digital Assets

Recent enforcement actions against banks indicate a new regulator emphasis on digital assets and Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance. Last year, Anchorage Digital Bank (Anchorage)—formerly Anchorage...more

Holland & Knight LLP

FINRA Issues Guidance on FinCEN AML/CFT Priorities

Holland & Knight LLP on

The Financial Industry Regulatory Authority (FINRA) issued a regulatory notice on Oct. 8, 2021, encouraging its broker-dealer members to review and prepare to incorporate into their own compliance programs the national...more

American Conference Institute (ACI)

[Event] 15th Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance - December 7th - 8th, Washington, DC

LIVE and IN-PERSON ACI’s Flagship Conference in December! ACI’s 15th Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance is North America’s largest and most comprehensive conference on economic...more

Jones Day

SEC’s Division of Examinations Signals Continuing Focus on Broker-Dealer AML Compliance Obligations

Jones Day on

The Situation: The Securities and Exchange Commission’s Division of Examinations ("EXAMS") released a Risk Alert on March 29, 2021, reminding broker-dealers of their obligation to comply with anti-money laundering ("AML")...more

WilmerHale

CFTC 2020 Enforcement and Regulatory Developments and a Look Forward

WilmerHale on

2020 saw continuity in CFTC leadership, programs, and direction from 2019. Overall, the Commission enjoyed an unusually heavy rulemaking calendar and continued the direction of its enforcement program from 2019. On the...more

American Conference Institute (ACI)

[Virtual Event] Navigating Russia Sanctions Complexities - November 9th - 10th, 8:30 am - 12:30 pm EST

In light of continued demand for dedicated Russia sanctions content, ACI and C5 are delighted to hold the 3rd Navigating Russia Sanctions Complexities, this year in a virtual format. This highly anticipated event is...more

Proskauer - The Capital Commitment

FinCEN Explains What Guides Its Enforcement Decisions

On August 18, 2020, the Financial Crimes Enforcement Network (FinCEN), which is the primary regulator and administrator of the Bank Secrecy Act (BSA), issued a statement on enforcement of the BSA. The requirements of the BSA...more

American Conference Institute (ACI)

[Webinar] Virtual Berlin Forum on Global Economic Sanctions - September 14th - 16th, 1:00 pm - 5:30 pm CEST

C5's Virtual 14th Berlin Forum on Global Economic Sanctions is next week. Navigating the rapidly changing sanctions landscape and staying compliant is hard. Don’t miss this unique opportunity to hear from the most experienced...more

Foley & Lardner LLP

FinCEN Expands View of Compliance Requirements

Foley & Lardner LLP on

On August 18, 2020, the Financial Crimes Enforcement Network (FinCEN) issued a statement on its approach to enforcing the Bank Secrecy Act (BSA), to provide clarity on its approach to bringing compliance or enforcement...more

Ballard Spahr LLP

Federal Banking Agencies Issue Joint Statement On Enforcement of BSA/AML Requirements; FinCEN Follows With Its Own

Ballard Spahr LLP on

Regulators Provide Greater Transparency into BSA/AML Enforcement Process - On August 13, 2020 the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the...more

Ward and Smith, P.A.

Should You Bank a Virtual Currency Business?

Ward and Smith, P.A. on

Virtual currencies like Bitcoin and Ethereum have spawned many types of businesses that need banking services. Many banks "de-risk" -- do not provide banking services -- to these businesses. Many virtual currency...more

Wilson Sonsini Goodrich & Rosati

Anti-Money Laundering Obligations for Virtual Currency Companies

Virtual currency businesses are under scrutiny by U.S. anti-money laundering (AML) regulators. Earlier this year, U.S Treasury Secretary Steven Mnuchin emphasized that virtual currencies are subject to AML regulations. He...more

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