News & Analysis as of

Consent Order Anti-Money Laundering

Sheppard Mullin Richter & Hampton LLP

FDIC and Maryland End Joint Consent Orders Against Regional Bank

On April 7, the FDIC and the Maryland Office of Financial Regulation terminated two consent orders against a regional bank headquartered in Maryland. The termination concludes joint federal and state enforcement actions that...more

Troutman Pepper Locke

Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast

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In this episode of Payments Pros, host Carlin McCrory discusses a recent consent order between Patriot Bank and the Office of the Comptroller of the Currency (OCC) following a $27 million loss. The order addresses unsafe...more

Ballard Spahr LLP

FinCEN Issues Consent Order Against Card Club for “Fundamentally Unsound” AML Program

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The Financial Crimes Enforcement Network (“FinCEN”) has entered into a Consent Order with the Sahara Dunes Casino, doing business as the Lake Elsinore Hotel and Casino (“Lake Elsinore”).  The Consent Order describes Lake...more

Ballard Spahr LLP

NYDFS Imposes $35 Million Fine on Nordea Bank for Alleged AML Failures Following Panama Papers Revelations

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On August 27, 2024, the New York State Department of Financial Services (“NYDFS”) announced a consent order involving a $35 million settlement with Nordea Bank Abp (“Nordea”) for alleged significant failures related to...more

Arnall Golden Gregory LLP

Q&A With Allison Raley: Defending Against Government Investigations

Q: What are the primary areas of focus in your practice related to government investigations? A: My practice primarily focuses on defense against enforcement actions brought by regulatory bodies such as the Office of Foreign...more

Sheppard Mullin Richter & Hampton LLP

FDIC Issues Orders Against Two More Banks Over Fintech Partnerships

In the FDIC’s latest monthly update on enforcement decisions and orders, the agency published recent consent orders it entered against both a New York-based and an Ohio-based bank, the latest in the agency’s series of...more

Ballard Spahr LLP

Recent FDIC Consent Orders Reflect Ongoing Scrutiny of Bank Relationships with Fintechs

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In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness concerns relating...more

Ballard Spahr LLP

Recent FDIC consent orders show increased regulation scrutiny of bank relationships with fintech partners

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In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness, compliance with...more

Ballard Spahr LLP

ICBC Agrees to Two Consent Orders for Alleged BSA/AML Deficiencies and Disclosure of Confidential Supervisory Information

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Recently, the Industrial and Commercial Bank of China Ltd. (“ICBC”) entered into two consent orders. The first consent order is with the New York State Department of Financial Services (the “NYDFS”) for alleged deficiencies...more

Ballard Spahr LLP

SDNY Grants Ex Parte Applicants the Ability to Subpoena Deutsche Bank Entities as Part of Ongoing AML-Related Litigation Against...

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On December 14, 2023, the United States District Court for the Southern District of New York (the “Court”) granted an unusual ex parte application to serve third-party discovery subpoenas on U.S.-based Deutsche Bank entities....more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - December 2023

Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more

Troutman Pepper Locke

Understanding the DOJ’s Groundbreaking $4.3B Settlement with Foreign Cryptocurrency Exchange Binance.com

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On November 21, the U.S. Department of Justice (DOJ) unsealed its criminal indictment against Binance.com (Binance), the world’s largest cryptocurrency exchange, and its CEO, Changpeng “CZ” Zhao (CZ). The indictment against...more

Ballard Spahr LLP

Binance Settles Criminal and Civil AML and Sanctions Enforcement Actions for Multiple Billions – While its Founder, Owner and...

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As the world now knows, Binance Holdings Limited, doing business as Binance.com (“Binance” or the “Company”), has entered into a plea agreement with the U.S. Department of Justice (“DOJ”)....more

Ballard Spahr LLP

FinCEN Issues $15 Million Dollar Civil Penalty Against Shinhan Bank America for Alleged Failure to Implement and Maintain...

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On September 29, the Financial Crimes Enforcement Network (“FinCEN”) entered into a consent order with Shinhan Bank America (“SHBA”), which imposed a $15 million dollar civil penalty against SHBA for allegedly willfully...more

Morrison & Foerster LLP

Enforcement Alert: FinCEN Leverages “Gap Rule” for Violations of the Bank Secrecy Act

On September 15, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced its first “Gap Rule” enforcement action in a Consent Order with Bancrédito International Bank and Trust...more

BakerHostetler

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

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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

Orrick, Herrington & Sutcliffe LLP

Crypto platform reaches $100 million settlement to resolve alleged compliance failures

On January 4, NYDFS issued a consent order against a cryptocurrency trading platform for engaging in alleged violations of New York virtual currency, anti-money laundering, transaction monitoring, and cybersecurity...more

ArentFox Schiff

Investigations Newsletter: Court Rejected Former Theranos Executive Sunny Balwani's Request For New Trial

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Court Rejected Former Theranos Executive Sunny Balwani’s Request For New Trial - On October 11, 2022, a California federal court rejected former Theranos Chief Operating Officer Sunny Balwani’s request for a new trial,...more

BakerHostetler

New York State Department of Financial Services Publishes First Crypto Industry Consent Order

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​​​​​​​On August 1, 2022, the New York State Department of Financial Services (“DFS” or “Department”) issued a Consent Order, imposing a $30 million fine on Robinhood Crypto, LLC (“Robinhood”), a trading platform that allows...more

Sheppard Mullin Richter & Hampton LLP

OCC and FinCEN Issue $200 Million in Penalties for BSA-AML Violations

On March 17, the OCC and FinCEN issued civil monetary penalties against a federal savings bank for “willfully” failing to meet minimum compliance program requirements and shoddy suspicious transaction reporting. The consent...more

Sheppard Mullin Richter & Hampton LLP

OCC and FinCEN Issue $9 Million in Penalties for BSA-AML Violations

On December 16, 2021, the Office of the Comptroller of the Currency (“OCC”) and the Financial Crimes Enforcement Network (“FinCEN”) issued civil monetary penalties against a Texas community bank for violations of the Bank...more

BCLP

Continuing AML regulatory issue focus: A look at a recent SEC enforcement case, the SEC’s response to Petition for Certiorari, and...

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Garcia Case Highlights Necessity of Knowing Your Customer and Listening to Internal Fraud Watchdogs. The SEC’s recent Order against a broker-dealer (the “Firm”) imposed a $750,000 financial penalty for the Firm’s failure...more

WilmerHale

Recent OCC Actions Focus Attention on Financial Crime Controls for Cryptocurrency Custody Businesses

WilmerHale on

Two recent actions by the Office of the Comptroller of the Currency (OCC) - one enforcement action and one interpretive note - focus attention on the kinds of anti–money laundering (AML) controls needed for banks to custody...more

Ballard Spahr LLP

Former Bank General Counsel Enters into Consent Order Over Alleged AML Obstruction

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The Office of the Comptroller of Currency (“OCC”) issued an extraordinary announcement regarding the decision of a former bank general counsel – Daniel Weiss, formerly employed by Rabobank, N.A. – to enter into a Consent...more

Sullivan & Worcester

Object Lesson on How Not to Respond to Consent and Enforcement Actions

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Last week, the DFS announced an enforcement action and charges against the NY Branch of Habib Bank, a Pakistani bank that had been doing business in NY for almost 40 years....more

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