News & Analysis as of

Money Laundering Office of the Comptroller of the Currency

Troutman Pepper Locke

OCC Patriot Bank Order Spotlights AML Issues For Managers

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On Jan. 14, Patriot Bank, based in Stamford, Connecticut, entered into an agreement with the Office of the Comptroller of the Currency to address and rectify several alleged unsafe or unsound practices and violations of law....more

Bradley Arant Boult Cummings LLP

Community Banks and BSA/AML Compliance: The OCC’s Consent Order with Clear Fork Bank Proves Regulators Aren’t Only Focused on...

On October 10, 2024, the financial services community was stunned by the $3.1 billion settlement between the federal government and TD Bank over Bank Secrecy Act (BSA) and anti-money laundering (AML) violations. TD Bank’s...more

Latham & Watkins LLP

Landmark Bank Secrecy Act Resolution Signals Increasing Focus on Banks’ Anti-Money Laundering Compliance

Latham & Watkins LLP on

Enforcement agencies urge investment in compliance programs. On October 10, 2024, the Department of Justice (DOJ) announced plea agreements with TD Bank N.A. (TDBNA) and its parent company, TD Bank US Holding Company...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 Rotten Corporate Culture — From its Store-Level Operations to its Board’s Audit Committee (Part IV of IV)

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TD Banks’ complete compliance disaster was reflected in every aspect of TD Bank’s business and compliance operations. It is not surprising that TD Bank’s deficient BSA and AML compliance program was known by its Board of...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 4- Watergate, Actual Knowledge and Conscious Indifference

Mike Volkov often told the story of watching the Watergate Hearings as a teenager and being a seminal influence on his later professional life in the legal profession and government service. It was my first exposure to...more

Bradley Arant Boult Cummings LLP

TD Bank’s Historic $3.1B Money Laundering Settlement a Warning to All Financial Institutions

On October 10, 2024, Attorney General Merrick Garland announced that TD Bank agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice’s (DOJ) investigation into money laundering and Bank Secrecy...more

Lowenstein Sandler LLP

TD Bank to Pay Historic $3 Billion Over AML Compliance Violations

Lowenstein Sandler LLP on

On October 10, 2024, multiple U.S. federal and state agencies cumulatively fined a number of US based Toronto Dominion Bank subsidiaries (collectively, TD Bank or the Bank) more than $3 billion after finding that TD Bank...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 2 – When Profits Trump Compliance: A Recipe for Corporate Disaster

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

Troutman Pepper Locke

FDIC Proposes Increased Scrutiny of Bank Mergers

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Today, a divided Federal Deposit Insurance Corporation’s (FDIC) Board of Directors issued a proposed Statement of Policy (SOP) on bank merger transactions that would create a combined bank with more than $100 billion in...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

Ballard Spahr LLP

Former Bank Compliance Chief Seeks Appellate Review of OCC Administrative Enforcement Proceeding Dismissal

Ballard Spahr LLP on

In an unusual move, Laura Akahoshi, former Rabobank (the “Bank”) Chief Compliance Officer (“CCO”), filed on July 6, 2023 an opposition to the Office of the Comptroller of the Currency’s (“OCC”) dismissal of its own...more

Oberheiden P.C.

OCC Enforcement Defense: Avoiding Penalties for BSA Noncompliance

Oberheiden P.C. on

Noncompliance with the Bank Secrecy Act (BSA) can subject banks and other financial institutions to substantial penalties. As a result, it is critical that financial institution executives not only understand the BSA itself...more

Ballard Spahr LLP

Changes to Data Collection for OCC’s Money Laundering Risk System

Ballard Spahr LLP on

On September 8, the Office of the Comptroller of the Currency (“OCC”) published an extension of its notice and request for comment (the “Notice”) in the Federal Register regarding changes to the OCC’s Money Laundering Risk...more

King & Spalding

State Attorneys General Poised to Elevate Regulatory Scrutiny of Digital Asset Businesses

King & Spalding on

The Attorney General Alliance (“AGA”) recently issued a collaborative White Paper that signals heightened scrutiny of digital asset businesses by state Attorneys General in coming years. Recognizing that it is “no longer...more

Goodwin

FinCEN Warns Against Evasion of Russian Sanctions

Goodwin on

In this Issue. The Financial Crimes Enforcement Network (FinCEN) published an alert warning financial institutions of possible efforts to evade U.S.-imposed sanctions on Russia and Belarus; the U.S. Department of the Treasury...more

K2 Integrity

Crypto and Virtual Currency Risks

K2 Integrity on

The ABA/ABA Financial Crimes Enforcement Conference took place January 11-13, with K2 Integrity Managing Director Gabriel Hidalgo, who leads the firm’s Crypto and Fintech Advisory practice, leading an important conversation...more

Foodman CPAs & Advisors

Agencies Request Information To Assist With BSA Laws And Regulations Compliance

On April 9, 2021, the federal banking regulatory agencies (the Federal Reserve, FDIC and OCC) together with FinCEN and the National Credit Union Administration issued a joint statement addressing how risk management...more

Foodman CPAs & Advisors

While FinCEN lacks Independent Litigating Authority, it is the Regulator for the BSA and is responsible for the administration of...

FinCEN issues implementing regulations that “ensure” compliance with the BSA.  FinCEN delegates its examination authority to federal agencies.  These federal agencies are the “Federal Functional Regulators” who supervise...more

The Volkov Law Group

DOJ Cryptocurrency Guidance Outlines Enforcement Partnerships (Part II of II)

The Volkov Law Group on

DOJ’s Cyber Digital Task Force’s report, “Cryptocurrency: An Enforcement Framework,” provides a comprehensive on the growing partnerships between DOJ and other offices within the executive branch....more

Vinson & Elkins LLP

Cryptocurrency 101 – DOJ’s New Cryptocurrency Enforcement Framework Provides Guidance And Promises Of Heightened Scrutiny Of...

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On October 8, 2020, the Attorney General’s Cyber-Digital Task Force (“the Task Force”) issued its Cryptocurrency Enforcement Framework (the “Report”), which offers background on virtual assets, enforcement milestones, and...more

Foodman CPAs & Advisors

Are Banks Implementing BSA Risk Based Adjustments related to COVID-19 circumstances?

The Office of the Comptroller of the Currency (OCC) Semiannual Risk Perspective Report highlights how the Covid-19 Pandemic has elevated  operational risks for banks as they are challenged with the implementation of new...more

Eversheds Sutherland (US) LLP

Cryptocurrency misappropriation, hacking, theft and fraud on target for banner year

According to one blockchain and cryptocurrency security firm, this year is on pace to be the second highest in cryptocurrency theft, hacking and fraud, with January through May 2020 already seeing $1.36 billion stolen in...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

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