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Compliance Consent Order Enforcement Actions

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Goodwin

Supervisory Experience and Enforcement Actions Continue to Drive Supervisory Priorities and Policy Development

Goodwin on

This article identifies themes we have observed in recent public formal enforcement actions issued to institutions by the US federal bank regulatory agencies (Agencies) — the Board of Governors of the Federal Reserve System...more

Venable LLP

CFPB to Launch Registry of Nonbank Enforcement Actions

Venable LLP on

In a move that's sure to make nonbank financial institutions even more uncomfortable, the Consumer Financial Protection Bureau (CFPB) has decided to shine a brighter light on those that have been alleged to violate consumer...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Jefferson County Hazardous Waste Management...

The Alabama Department of Environmental Management (“ADEM”) and Safety-Kleen Systems, Inc. (“Safety-Kleen”) entered into a December 22nd Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste...more

Adams and Reese LLP

FDIC Sends Clear Message in Recent Enforcement Action: BaaS/Fintech Partnerships are a High-Risk Compliance Area

Adams and Reese LLP on

Last month, the Federal Deposit Insurance Corporation (“FDIC”) took action against a bank for alleged unsafe or unsound banking practices. This, in and of itself, is not usual or newsworthy. What is unusual and newsworthy,...more

Hudson Cook, LLP

In Latest "Repeat Offender" Salvo, CFPB Sues Mortgage Company for Alleged HMDA Reporting Violations

Hudson Cook, LLP on

The complaint, filed in the U.S. District Court for the Southern District of Florida, alleges that a non-bank residential mortgage loan originator violated the Home Mortgage Disclosure Act ("HMDA") by submitting inaccurate...more

BakerHostetler

NYS DFS Focuses on Cybersecurity Violations and Increasing Crypto Resources

BakerHostetler on

On May 1, 2023, the New York State Department of Financial Services (DFS or Department) issued a consent order (Consent Order), imposing a $1.2 million fine on bitFlyer USA, a cryptocurrency trading platform and custodial...more

BakerHostetler

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

BakerHostetler on

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

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Glencoe Commercial Hazardous Waste...

The Alabama Department of Environmental Management (“ADEM”) and American Transportation Solutions, LLC (“ATS”) entered into a December 14th Consent Order (“CO”) addressing an alleged violation of the Alabama Hazardous Waste...more

BakerHostetler

SEC Finds Investment Adviser CEO Liable for Failing to Supervise High-Risk Representative

BakerHostetler on

On Nov. 3, 2022, the SEC announced a consent order against a registered investment adviser (RIA) and its chief executive officer (CEO) for failing to reasonably supervise one of the RIA’s investment adviser representatives...more

Holland & Knight LLP

CFPB Targets Garnishment Practices: Banks Need a Robust Compliance Plan

Holland & Knight LLP on

When a consumer fails to pay a debt, the creditor may engage in proceedings to collect, which may result in a court issuing a garnishment notice directing a bank to freeze and turn over funds in the consumer's deposit account...more

BakerHostetler

Major U.S. Crypto Exchange Consents to $29 Million Penalty for Historic BSA and OFAC Violations

BakerHostetler on

​​​​​​​On October 11, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced a $29 million civil monetary penalty against Bittrex, a...more

Pillsbury Winthrop Shaw Pittman LLP

NYDFS Continues Series of Fair Lending Enforcement Actions against New York State-Chartered Banks

NYDFS is closely evaluating fair lending compliance at the institutions it regulates, and bringing enforcement actions based on statistical analyses of lenders’ loan portfolios. NYDFS has entered into a series of consent...more

Epiq

Five Qualities to Look for in a Third-Party Administrator

Epiq on

Financial institutions can face investigations from a number of regulatory bodies such as the Federal Reserve, U.S. Department of Justice, U.S. Securities and Exchange Commission, and Federal Trade Commission. Common topics...more

The Volkov Law Group

Dubai Bank Pays $100 Million to Resolve Sanctions Violations with DFS, OFAC and Federal Reserve

The Volkov Law Group on

Mashreqbank, based in Dubai, agreed to pay $100 million to the New York Department of Financial Services, the Federal Reserve, and the Office of Foreign Asset Control for violation of the now-repealed Sudan Sanctions...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Huntsville Solar Panel Manufacturing Facility...

The Alabama Department of Environmental Management (“ADEM”) and LG Electronics USA, Inc. (“LG”) entered into a January 6th Consent Order (“CO”) addressing alleged violations of the ADEM Administrative Code addressing...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

Sunstein LLP

Twenty Years Under the Microscope: A Small Business, a Data Breach and the FTC

Sunstein LLP on

James Grago has a nice business going. He runs a website called ClixSense.com that permits users to earn money by completing surveys and watching advertisements. Revenues grew from $6.7 million in 2015 to $9.1 million in...more

WilmerHale

New FTC Data Security Order Shows Trend in Increased Accountability for Data Security Post-Order

WilmerHale on

On June 12, 2019 Lightyear Dealer Technologies LLC, a company that provides data storage for many of the nation’s largest auto dealers, stipulated to an Order with the Federal Trade Commission (FTC) resulting from a 2016 data...more

The Volkov Law Group

Federal Reserve Hits Wells Fargo with Unprecedented Enforcement Action (Part I of II)

The Volkov Law Group on

In an extraordinary action, with significant ramifications for the financial industry, the Federal Reserve recently announced a series of enforcement actions against Wells Fargo....more

Smith Debnam Narron Drake Saintsing & Myers,...

CFPB Consent Orders Serve as a Reminder to Mortgage Industry on Advertising Practices

A recent series of CFPB consent orders should remind the mortgage industry to carefully monitor its advertising practices. The MAP Rule prohibits deceptive and misleading commercial communications regarding any term of any...more

Arnall Golden Gregory LLP

CFPB Enforcement Action Against Two Background Screeners

The Consumer Financial Protection Bureau (CFPB) announced that it has taken action against two large background screening companies.  Yes, you are reading this correctly.  The CFPB…not the Federal Trade Commission, has taken...more

Manatt, Phelps & Phillips, LLP

Add-On Products Add up to $63M Settlement With FDIC

Why it matters - Credit card add-on products were the subject of a recent enforcement action brought by the Federal Deposit Insurance Corporation (FDIC) against Comenity Bank of Delaware and Comenity Capital Bank in...more

The Volkov Law Group

SEC’s Hitachi Enforcement Action and Important Compliance Reminders

The Volkov Law Group on

The SEC continues to plug away at aggressive FCPA enforcement. This year, at least so far, the SEC has had a very successful year. The Hitachi case is a very interesting enforcement action for several major reasons. ...more

MoFo Reenforcement

One-Two Punch: CFPB Indirect Auto and Add-On Product Orders

MoFo Reenforcement on

The CFPB announced two new enforcement action settlements on September 28: one for alleged discriminatory auto loan pricing and the other for alleged deceptive credit card add-on product marketing practices....more

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