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Anti-Money Laundering Banks BSA/AML

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Board Penalizes Two Banks for Compliance Deficiencies

On November 13, the Federal Reserve Board issued two cease and desist orders against a state-chartered bank and a bank holding company for alleged compliance deficiencies. The Federal Reserve Board first order was against...more

Bradley Arant Boult Cummings LLP

$3B TD Bank AML Settlement Is A Wake-Up Call For All Banks

On Oct. 10, Attorney General Merrick Garland announced that TD Bank pled guilty to conspiracy to commit money laundering and agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice's...more

Orrick, Herrington & Sutcliffe LLP

OCC releases enforcement actions for October 2024

On October 17, the OCC released a list of recent enforcement actions taken against banks and individuals affiliated with national banks, federal savings associations and institution-affiliated parties, or IAPs. The OCC issued...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

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

Orrick, Herrington & Sutcliffe LLP

OCC releases FY 2025 bank supervision operating plan

On October 1, the OCC released its bank supervision operating plan for fiscal year (FY) 2025. The OCC outlined its supervision priorities and objectives which will guide the implementation of supervisory strategies for...more

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

Ballard Spahr LLP

Bank and Credit Union Industry Groups Challenge Illinois Interchange Fee Prohibition Act as Unlawful and Urge the Court to Stop...

Ballard Spahr LLP on

On August 15, 2024, the Illinois Bankers Association, American Bankers Association, America’s Credit Unions, and Illinois Credit Union League filed a complaint for declaratory and injunctive relief against the Illinois...more

Ballard Spahr LLP

Bank’s Digital Assets Business Strategy Draws Federal Reserve Scrutiny

Ballard Spahr LLP on

The Federal Reserve Bank of Philadelphia (the “Philly Fed”) recently executed an agreement (the “Agreement”) with Pennsylvania-based Customers Bank (and its Customers Bancorp, Inc. holding entity) (collectively, “Customers”)....more

Ballard Spahr LLP

FinCEN Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

Ballard Spahr LLP on

On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more

Freiberger Haber LLP

Enforcement News: SEC Charges Bank With Misleading Investors About The Strength Of Its BSA/AML Compliance Program And Its...

Freiberger Haber LLP on

The Currency and Foreign Transactions Reporting Act, also known as the “BSA,” enacted in 1970, established requirements for record-keeping and reporting by banks and other financial institutions. The BSA is designed to, among...more

Ballard Spahr LLP

Federal Banking Agencies Issue Guide to Third-Party Risk Management Practices for Community Banks

Ballard Spahr LLP on

On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the...more

Cadwalader, Wickersham & Taft LLP

FinCEN’s Proposed Rulemaking: Enhancing Transparency in Residential Real Estate

While many Americans are struggling to achieve the dream of homeownership, there are criminals that abuse the housing market for financial gain. To avoid the scrutiny of financial institutions that have anti-money laundering...more

Morgan Lewis - All Things FinReg

OCC Proposes Substantive and Procedural Revisions for Bank Mergers

The US Office of the Comptroller of the Currency (OCC) on January 29 proposed meaningful revisions to its rules and processes for reviewing proposed transactions involving national banks under the Bank Merger Act. The...more

Ballard Spahr LLP

Criminal Case Round-Up: Recent Prosecutions Involving Casinos

Ballard Spahr LLP on

The Department of Justice (“DOJ”) has been very active in the Bank Secrecy Act (“BSA”) / Anti-Money Laundering (“AML”) space, as reflected by a recent series of individual prosecutions and corporate non-prosecution agreements...more

Orrick, Herrington & Sutcliffe LLP

NYDFS and Fed order bank to pay fines for BSA/AML non-compliance

On January 19, the Federal Reserve Board and NYDFS each issued separate enforcement actions against one of the largest banks in the world for alleged compliance deficiencies and violations under BSA/AML. The Fed issued its...more

Ballard Spahr LLP

OCC Risk Perspective Report Focuses on Third-Party Relationships with Fintechs

Ballard Spahr LLP on

In its Fall 2023 Semiannual Risk Perspective, published on December 7, the Office of the Comptroller of the Currency (“OCC”) reported on key issues facing the federal banking system. In evaluating the overall soundness of...more

Ballard Spahr LLP

Bipartisan Group of Senators Re-Introduce the Digital Asset Money Laundering Act

Ballard Spahr LLP on

Legislation Targets Unhosted Wallets, Validators and Digital Asset ATMs - On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the...more

The Volkov Law Group

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

The Volkov Law Group on

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

Orrick, Herrington & Sutcliffe LLP

OCC releases enforcement actions

On March 17, the OCC released a list of recent enforcement actions taken against national banks, federal savings associations, and individuals currently and formerly affiliated with such entities. ...more

J.S. Held

Risky Business: How Fintech Firms Can Build Better AML and Sanctions Risk Assessments

J.S. Held on

The year 2023 promises to be exciting for Fintech. On the upside, the web 3.0 economy is poised for significant growth as decentralization favors creatives and community with its lower costs and lower barriers to entry...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

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