Compliance into the Weeds: Settlement of OCC Charges for Wells Fargo Internal Auditors
Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast
2024 Payments Year in Review: CFPB and FTC Regulatory Trends – Part Four — Payments Pros – The Payments Law Podcast
Compliance Tip of the Day: TD Bank Lessons Learned – The Penalty of Growth Restrictions
Climate Risk, the emerging risk
Consumer Finance Monitor Podcast Episode: Community Reinvestment Act Reform: A Close Look at the Final Rule
Consumer Finance Monitor Podcast Episode: What the Recent Developments in Federal Preemption for National and State Banks Mean for Bank and Nonbank Consumer Financial Services Providers
Federal Banking Interagency Final Guidance on Third-Party Relationships - The Consumer Finance Podcast
Corruption, Crime and Compliance : CFPB and OCC Hit Bank of America with $250 Million Penalty for Consumer Abuse Practices
CFPB's Section 1071 Final Rule (Part 3): Potential Problem Areas – The Consumer Finance Podcast
Crypto Year in Review 2022: Federal Reserve and Central Bank Digital Currencies and FDIC/OCC Regulatory Developments - The Crypto Exchange Podcast
Crypto Enforcement Is Here, and Always Has Been
Congressional and Federal Agency Action Following Executive Order on Digital Assets Policy
Guidepost in Motion: Banking on Crypto
Compliance into the Weeds: Episode 161-OCC Guidance on 3rd Party Risk Management
Episode 127 -- Deep Dive into the OCC Enforcement Action Against Wells Fargo CEO and Senior Executives
Dealing with an Unsolicited Offer - The Bank Account
The Community Reinvestment Act (CRA): Recap and What to Expect in 2014
The New Normal: Taking Responsibility for Your Vendors
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
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
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
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
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
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
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
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 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
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
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
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
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
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 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
Compliance professionals face extraordinary risks – not just for the enterprise but personal risks. CCOs should not panic or overreact when the government brings an enforcement action against a compliance officer for a...more
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
When assessing anti-money laundering risk and exposure, global financial institutions should be mindful of the complex landscape and assertions of broad authority by U.S. authorities and banking regulators. A multinational...more
First Post in a Two-Part Series - Late last week, the U.S. Senate Committee on Banking, Housing, and Urban Affairs (the “Banking Committee”) met in open session to conduct a hearing on “Combating Money Laundering and Other...more
The Federal Banking Agencies (“FBAs”) — collectively the Office of the Comptroller of the Currency (“OCC”); the Board of Governors of the Federal Reserve System (“Federal Reserve”); the Federal Deposit Insurance Corporation...more
OCC Identifies AML/BSA and Cyber Threats as Elevated Risks Facing Banks - Last week, the Office of the Comptroller of the Currency (“OCC”) published the Spring 2018 Semiannual Risk Perspective (the “Report”), which uses...more
Recently, an American bank entered into a deferred prosecution agreement requiring it to pay over US$610 million in penalties. The plea agreement was based on “impos[ing] hard caps on the number of transactions subject to AML...more
Financial Industry Developments - OCC Provides Additional Details to Evaluate Charter Applications From Fintech Companies - On March 15, 2017, the Office of the Comptroller of the Currency ("OCC") issued a "Draft...more
In his remarks at the LendIt Conference in New York, Comptroller of the Currency Tom Curry discussed the special purpose national bank charters to be granted by the OCC to fintech companies and addressed the various...more