News & Analysis as of

Financial Crimes Office of the Comptroller of the Currency

Davis Wright Tremaine LLP

Bank Regulatory Considerations in a Second Trump Administration – What Could Change, What Could Stay the Same

While the coming weeks and months will provide more clarity, we already can anticipate some indications of what is in store for bank regulation, supervision, and enforcement in a second Trump Administration. To help navigate...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)

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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

Lowenstein Sandler LLP

TD Bank to Pay Historic $3 Billion Over AML Compliance Violations

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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

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

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

Orrick, Herrington & Sutcliffe LLP

OCC highlights recent enforcement actions

On September 19, 2024, the OCC released a list of recent enforcement actions against a federal savings bank, a national bank, and an individual affiliated with a national bank (an institution-affiliated party, or IAP)....more

Ballard Spahr LLP

Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

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The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

The Volkov Law Group

Sterling Bank’s ex-General Counsel hit with OCC Cease-and-Desist over Longstanding BSA/AML Shortcomings

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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

Paul Hastings LLP

Daily Financial Regulation Update -- Wednesday, February 14, 2024

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February 13, 2024- The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking to keep criminals and foreign adversaries from exploiting the U.S. financial...more

Ballard Spahr LLP

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

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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

Paul Hastings LLP

Daily Financial Regulation Update -- Tuesday, December 12, 2023

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December 11, 2023- The U.S. Department of the Treasury published a fact sheet entitled, "U.S. Department of the Treasury Actions to Prevent and Disrupt Corruption" following up on the U.S. Strategy on Countering...more

Paul Hastings LLP

Daily Financial Regulation Update -- Wednesday, August 16, 2023

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August 15, 2023- Consumer Financial Protection Bureau Director Rohit Chopra gave remarks at the White House Roundtable on Protecting Americans from Harmful Data Broker Practices....more

Ballard Spahr LLP

Former Bank Compliance Chief Seeks Appellate Review of OCC Administrative Enforcement Proceeding Dismissal

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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

Paul Hastings LLP

Daily Financial Regulation Update -- Friday, June 30, 2023

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June 29, 2023- Federal financial institution regulatory agencies today jointly issued a final policy statement on commercial real estate loan accommodations and workouts....more

Paul Hastings LLP

Daily Financial Regulation Update -- Saturday, May 27, 2023

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U.S. House Financial Services Committee Chairman Patrick McHenry (NC-10) sent a letter to Secretary of the Treasury Janet Yellen regarding Treasury's rumored Executive Order on outbound investment to China....more

The Volkov Law Group

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

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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

Paul Hastings LLP

Daily Financial Regulation Update -- Saturday, July 2, 2022

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Major Developments- Justice Department Announces Enforcement Action Charging Six Individuals with Cryptocurrency Fraud Offenses in Cases Involving Over $100 Million in Intended Losses...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

Foodman CPAs & Advisors

Agencies Request Information To Assist With BSA Laws And Regulations Compliance

On April 9, 2021, the federal banking regulatory agencies (the Federal Reserve, FDIC and OCC) together with FinCEN and the National Credit Union Administration issued a joint statement addressing how risk management...more

Foodman CPAs & Advisors

While FinCEN lacks Independent Litigating Authority, it is the Regulator for the BSA and is responsible for the administration of...

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 Volkov Law Group

DOJ Cryptocurrency Guidance Outlines Enforcement Partnerships (Part II of II)

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DOJ’s Cyber Digital Task Force’s report, “Cryptocurrency: An Enforcement Framework,” provides a comprehensive on the growing partnerships between DOJ and other offices within the executive branch....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

Ballard Spahr LLP

FinCEN, OCC and FBI Offer Diverging Views on AML Reform in U.S. Senate Testimony

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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

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