News & Analysis as of

Consent Order BSA/AML

Ballard Spahr LLP

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

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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

Sheppard Mullin Richter & Hampton LLP

Fed Cracks Down on Utah Bank for Alleged Compliance Failures with $44 Million Fine

On a July 19, the Federal Reserve Board announced it has issued a consent order against a Utah-based bank and its parent company for engaging in unfair and deceptive acts and practices in violation of Section 5(a)(1) of the...more

Ballard Spahr LLP

ICBC Agrees to Two Consent Orders for Alleged BSA/AML Deficiencies and Disclosure of Confidential Supervisory Information

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Recently, the Industrial and Commercial Bank of China Ltd. (“ICBC”) entered into two consent orders. The first consent order is with the New York State Department of Financial Services (the “NYDFS”) for alleged deficiencies...more

Ballard Spahr LLP

SDNY Grants Ex Parte Applicants the Ability to Subpoena Deutsche Bank Entities as Part of Ongoing AML-Related Litigation Against...

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On December 14, 2023, the United States District Court for the Southern District of New York (the “Court”) granted an unusual ex parte application to serve third-party discovery subpoenas on U.S.-based Deutsche Bank entities....more

Troutman Pepper

Understanding the DOJ’s Groundbreaking $4.3B Settlement with Foreign Cryptocurrency Exchange Binance.com

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On November 21, the U.S. Department of Justice (DOJ) unsealed its criminal indictment against Binance.com (Binance), the world’s largest cryptocurrency exchange, and its CEO, Changpeng “CZ” Zhao (CZ). The indictment against...more

Ballard Spahr LLP

FinCEN Issues $15 Million Dollar Civil Penalty Against Shinhan Bank America for Alleged Failure to Implement and Maintain...

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On September 29, the Financial Crimes Enforcement Network (“FinCEN”) entered into a consent order with Shinhan Bank America (“SHBA”), which imposed a $15 million dollar civil penalty against SHBA for allegedly willfully...more

Orrick, Herrington & Sutcliffe LLP

Crypto platform reaches $100 million settlement to resolve alleged compliance failures

On January 4, NYDFS issued a consent order against a cryptocurrency trading platform for engaging in alleged violations of New York virtual currency, anti-money laundering, transaction monitoring, and cybersecurity...more

BakerHostetler

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

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​​​​​​​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

White & Case LLP

New York State Department of Financial Services Imposes $30 Million Fine in First Cryptocurrency Enforcement Action

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On August 2, in its first ever cryptocurrency enforcement action, the New York State Department of Financial Services ("NYDFS") announced it had imposed a $30 million fine on Robinhood Crypto, LLC ("RHC") for failures in its...more

BakerHostetler

New York State Department of Financial Services Publishes First Crypto Industry Consent Order

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​​​​​​​On August 1, 2022, the New York State Department of Financial Services (“DFS” or “Department”) issued a Consent Order, imposing a $30 million fine on Robinhood Crypto, LLC (“Robinhood”), a trading platform that allows...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

Sheppard Mullin Richter & Hampton LLP

OCC and FinCEN Issue $9 Million in Penalties for BSA-AML Violations

On December 16, 2021, the Office of the Comptroller of the Currency (“OCC”) and the Financial Crimes Enforcement Network (“FinCEN”) issued civil monetary penalties against a Texas community bank for violations of the Bank...more

WilmerHale

Recent OCC Actions Focus Attention on Financial Crime Controls for Cryptocurrency Custody Businesses

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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

Morrison & Foerster LLP

Financial Services Report, Summer 2020

Is it just us or does March 4 — the date of our last issue — feel like a million years ago? Like you, and not necessarily in this order, we have been: doing our work; keeping up with COVID-19-related laws, guidance, and...more

Ballard Spahr LLP

Former Bank General Counsel Enters into Consent Order Over Alleged AML Obstruction

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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

Manatt, Phelps & Phillips, LLP

Federal Reserve, FDIC Enforcement Efforts

In recent enforcement actions, the Board of Governors of the Federal Reserve System announced an order with a Japanese bank over weaknesses with respect to its New York branch’s Bank Secrecy Act / anti-money laundering...more

Morrison & Foerster LLP

Financial Services Report, Fall 2018

EDITOR’S NOTE - So much for the lazy days of summer. It’s been a busy couple of months on both coasts. In a case of déjà vu all over again, a New York federal court found that the CFPB structure is unconstitutional and that...more

Morrison & Foerster LLP

Financial Services Report - Summer 2017

EDITOR’S NOTE - Summer blockbuster season is officially upon us. Have you seen Wonder Woman yet? What about Guardians of the Galaxy Part 2? It’s déjà vu all over again with Baywatch, Pirates of the Caribbean, Alien,...more

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