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Anti-Money Laundering Compliance Office of the Comptroller of the Currency

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)

The Volkov Law Group on

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

The Volkov Law Group

TD Bank’s $3 Billion Settlement: A Review of Regulatory Settlements  (Part III of IV)

The Volkov Law Group on

TD Bank’s $3 billion settlement included coordinated regulatory settlements with the Federal Reserve Board (“Federal Reserve”), The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), and the...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

The Volkov Law Group

TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations (Part I of IV)

The Volkov Law Group on

In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion...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

Cadwalader, Wickersham & Taft LLP

Business As Usual, October 2024 - OCC Releases 2025 Bank Supervision Operating Plan

The Office of the Comptroller of the Currency’s Committee on Bank Supervision sets the agency’s supervision objectives and priorities. On October 1, the Committee released the OCC’s Bank Supervision Operating Plan (the...more

WilmerHale

FinCEN’s Proposed AML/CFT Program Rule Potentially Heralds a Change in Approach

WilmerHale on

On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...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

Sheppard Mullin Richter & Hampton LLP

South Dakota Lenders on Tight Deadline for BSA/AML Compliance

On January 12, South Dakota’s Division of Banking issued a mandate setting March 31, 2024 as the deadline for all South Dakota licensed money lenders and non-residential mortgage brokers to comply with their Bank Secrecy...more

Jenner & Block

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

Jenner & Block on

As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...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

Eversheds Sutherland (US) LLP

Stablecoins: some key regulatory and enforcement initiatives of US regulators

During the past few months, the US Treasury, the US banking agencies, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have pursued several regulatory or enforcement initiatives...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

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

Kelley Drye & Warren LLP

Former US Bank Exec Held Individually Liable for Anti-Money Laundering

Compliance Failures - On March 4, 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a consent order assessing a $450,000 civil money penalty against Michael LaFontaine, former Chief...more

The Volkov Law Group

United Bank Risk Officer Agrees to $450k Penalty for AML Compliance Failures

The Volkov Law Group on

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

Eversheds Sutherland (US) LLP

The OCC’s 2019 annual report addresses anti-money laundering risks for financial institutions

The Office of Comptroller of the Currency (the OCC) has published its 2019 annual report (the Annual Report), which summarized the OCC’s strategic priorities for 2019. The Annual Report also highlighted the OCC’s key...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

White & Case LLP on

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

Rabobank Coughs Up $368 Million and Pleads Guilty to Conspiracy to Money Launder and Obstruct Investigation

The Volkov Law Group on

The Justice Department announced a guilty plea by a subsidiary of Rabobank, a Dutch global bank, to a conspiracy to violate money laundering laws and obstruct a regulatory investigation of Rabobank’s activities in California....more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Enforcement Action Highlights AML Compliance Program Failures and Conflicts of Interest for High-Risk MSB Customers

On February 27, 2017, FinCEN announced a $7 million civil monetary penalty against Merchants for willful violations of the BSA. Additionally, the Office of the Comptroller of the Currency (OCC), Merchants’ federal functional...more

A&O Shearman

US Office of the Comptroller of the Currency Releases Bank Supervision Operating Plan for Fiscal Year 2017

A&O Shearman on

The US Office of the Comptroller of the Currency released its bank supervision operating plan for fiscal year (FY) 2017. The plan sets forth the foundation for policy initiatives and for supervisory strategies applicable to...more

Carlton Fields

Anti-Money Laundering Trends: Facts, Findings, and Lessons Learned

Carlton Fields on

Increased anti-money laundering (AML) regulation enforcement by federal and state agencies in recent months should have financial institutions across the country reviewing and strengthening their in-house AML policies and...more

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