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Compliance Enforcement Actions Banks

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 -
Cadwalader, Wickersham & Taft LLP

FinCEN Uses the FEND Off Fentanyl Act for First Time to Prohibit Funds Transfers with Three Mexican Financial Institutions

On June 25, 2025, FinCEN announced its first orders under the 2024 FEND Off Fentanyl Act, finding that three Mexican financial institutions—CIBanco S.A. Institución De Banca Multiple (“CIBanco"), Intercam Banco S.A.,...more

GeoDataVision

The New Modern Community Reinvestment Act Needs to be Fixed ASAP

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When the new CRA rule was published in late 2023 it contained some very serious flaws that need to be corrected. Fixing the flawed CRA rule should be a high priority for the Trump Administration because the new rule is...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

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

Adams & Reese

FDIC Sends Clear Message in Recent Enforcement Action: BaaS/Fintech Partnerships are a High-Risk Compliance Area

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Last month, the Federal Deposit Insurance Corporation (“FDIC”) took action against a bank for alleged unsafe or unsound banking practices. This, in and of itself, is not usual or newsworthy. What is unusual and newsworthy,...more

Orrick, Herrington & Sutcliffe LLP

Bank to pay $1 billion to settle investors’ compliance claims

Last month, the U.S. District Court for the Southern District of New York preliminarily approved a securities litigation settlement that would require a national bank to pay $1 billion to resolve class claims that it...more

The Volkov Law Group

TD Bank Eats $225 Million Termination Fee After AML Failures Doom Merger

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How much is an effective Anti-Money Laundering (“AML”) Compliance Program Worth? For Toronto-Dominion Bank (“TD”), the answer is at least $225 million––the amount that TD must now pay to First Horizon Bank, after backing...more

The Volkov Law Group

Wells Fargo Fumbles Sanctions Compliance Demonstrating An Absence of Culture of Compliance (Part II of II)

The Volkov Law Group on

Not that I am a glutton for punishment, but I always find enforcement actions to supply a number of valuable lessons learned. There are always instructive nuggets of information, opportunities missed, and root causes that...more

Venable LLP

Bank Provider of BaaS Dinged by OCC; Blueprint for Fintech Partnerships?

Venable LLP on

​​​​​​​A recent action by the Office of the Comptroller of the Currency (OCC) highlights how banks need to ensure that they have robust compliance programs for managing risks posed by their banking as a service (BaaS)...more

StoneTurn

No One Wants a Monitor, But… Part 3: Lessons Learned from Monitorships

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What was it like to be at one of the world’s largest companies while it was subject to a monitor? In this episode, Cindy Moehring highlights some of the key lessons learned from working with a monitor, and taps into Michele...more

StoneTurn

No One Wants a Monitor, But… Part 2: Working with a Monitor

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Monitorship: a term typically met with fear, but it doesn’t have to be. What’s at stake when a monitor comes on board? Are there global considerations at play? Cindy Moerhing, Michele Edwards and Emilia Drozda highlight keys...more

StoneTurn

No One Wants a Monitor, But… Part 1: The Landscape

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As the regulatory landscape changes across the globe, how will monitorships fit into the puzzle? In this episode, Cindy Moehring, former Chief Ethics and Compliance Officer (U.S.) for Walmart, sits down with StoneTurn’s...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

The Volkov Law Group

OFAC Ends 2020 with Two Enforcement Actions

The Volkov Law Group on

OFAC reported two new enforcement actions in the week between Christmas and New Year’s.  The two new enforcement actions are interesting examples of sanctions enforcement, one of which involved the first against a digital...more

The Volkov Law Group

Citigroup Fined $400 Million by Banking Regulators for Risk and Compliance Control Deficiencies

The Volkov Law Group on

Banking regulators, the Office of Comptroller of the Currency and the Federal Reserve, recently collected a $400 million civil penalty against Citigroup for long-standing deficiencies in its enterprise risk management,...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

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

Eversheds Sutherland (US) LLP

The DOJ issues its first FCPA advisory opinion after six years of silence

On August 14, 2020, the US Department of Justice (the DOJ) issued its first Foreign Corrupt Practices Act (FCPA) Opinion Procedure Release in six years, which relayed that it did not intend to pursue an enforcement action...more

Sheppard Mullin Richter & Hampton LLP

Fed’s Vice Chair for Supervision Proposes a Deregulatory Approach to Limit the Scope of “Matters Requiring Attention” used in Bank...

A January proposal to give banks compliance slack floated by a high-ranking Federal Reserve Board (“FRB”) official has not yet gained the traction its supporters had hoped for. In remarks before the American Bar Association...more

Robins Kaplan LLP

Financial Daily Dose 12.20.2019 | Goldman nearing $2B deal with DOJ to resolve 1MDB scandal claims

Robins Kaplan LLP on

Goldman Sachs is reportedly in negotiations with federal prosecutors to resolve claims about its role in the Malaysian 1MDB scandal for upwards of $2 billion. A settlement—which “could include a guilty plea from Goldman’s...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

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TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more

The Volkov Law Group

Financial Institutions and the Glaring Absence of an Ethical Culture

The Volkov Law Group on

Federal prosecutors and regulators have been active in tackling US banks. In the last few weeks, the Federal Reserve took the extraordinary step of blocking Wells Fargo’s ability to grow its business until it improves its...more

Skadden, Arps, Slate, Meagher & Flom LLP

New York Cybersecurity Regulations Could Affect Foreign Banks

Financial institutions covered by the New York State Department of Financial Services’ (NYDFS) new Cybersecurity Requirements for Financial Services Companies must file their first annual certification by February 15, 2018....more

Skadden, Arps, Slate, Meagher & Flom LLP

France Announces Its First Deferred Prosecution Agreement

In a move that could signal a new phase of government enforcement in France, on November 27, 2017, French authorities published a Convention judiciaire d’intérêt public (CJIP) with HSBC Private Bank Suisse SA (HSBC PB), the...more

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