News & Analysis as of

NYDFS Enforcement Actions Anti-Money Laundering

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

Jenner & Block

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

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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

Jenner & Block

Client Alert: New multi-front Enforcement Action Emphasizes Key AML Compliance Requirements

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Shinhan Bank America (“Shinhan”), a New York-based subsidiary of a Korean bank, faced coordinated enforcement actions on September 29 from the Financial Crimes Enforcement Network (“FinCEN”), Federal Deposit Insurance...more

BakerHostetler

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

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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

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

Moore & Van Allen PLLC

Banks – What Should You Know? Civil Liability for Failure to Detect Human Trafficking

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In 2020, we wrote about the increased regulatory attention on financial institutions’ obligations to detect and respond to human trafficking. In 2021, we wrote about how anti-human trafficking programs fit squarely in banks’...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

Foley Hoag LLP - White Collar Law &...

NY Department of Financial Services Slaps $30 Million Fine on Robinhood’s Crypto Platform for Lax Anti-Money Laundering Controls

On August 1, 2022, the New York Department of Financial Services (“DFS” or the “Department”) secured its first enforcement win against a cryptocurrency platform, Robinhood’s crypto trading arm Robinhood Crypto, LLC....more

Proskauer - Blockchain and the Law

New York Financial Regulator Brings First AML and Cybersecurity Enforcement Action against Licensed Crypto Trading Entity

In what is the New York Department of Financial Services’ (NYDFS) first enforcement action against a NYDFS-licensed “virtual currency business,” on August 1, 2022, the agency announced $30 million settlement with...more

Robinson+Cole Data Privacy + Security Insider

New York DFS Fines Robinhood $30M for “Significant” Cybersecurity Violations

The New York Department of Financial Services (DFS) announced its first ever penalty against a cryptocurrency platform this week, with a whopping $30 million fine assessed against Robinhood Crypto, LLC (RHC) for what it...more

BakerHostetler

Ethereum Fork Successful, Solutions Target Sneakers and Browsers, EU and NY Consider Regulations, Enforcement Actions Continue

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Ethereum Fork Implemented, Exchanges Expand Services, New Bitcoin Network Data - The Ethereum network’s Istanbul hard fork went forward late last week with the support of node operators, miners and cryptocurrency exchanges. ...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

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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

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update - January 2019

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including DOJ guidance on the use of corporate monitors in criminal...more

Perkins Coie

Blockchain Week in Review - December 2018

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U.S. Developments - SEC Remarks on International Virtual Currency Enforcement - On December 5, 2018, Steven Peikin, Co-Director of the Division of Enforcement at the U.S. Securities and Exchange Commission (“SEC”), gave a...more

Ballard Spahr LLP

Practical Tips in Action: The Mashreqbank AML Enforcement Action

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NYDFS Action Highlights the Need for Good Monitoring – and Good Consultants - In part one of this two-part post, we provided some practical tips for financial institutions to increase the chances that their Anti-Money...more

Moore & Van Allen PLLC

Anti-Money Laundering and Bank Secrecy Act Update

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After the Panama Papers exposed efforts by wealthy individuals and government officials to hide funds offshore, government authorities around the world have responded with new legislation, regulations and enforcement actions...more

Sullivan & Worcester

Object Lesson on How Not to Respond to Consent and Enforcement Actions

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Last week, the DFS announced an enforcement action and charges against the NY Branch of Habib Bank, a Pakistani bank that had been doing business in NY for almost 40 years....more

Manatt, Phelps & Phillips, LLP

Corporate Investigations & White Collar Defense - September 2015

No Dog Days of August for the SEC—A Recap of a Busy Month - Why it matters: Who says there is a government slowdown in August? Not for the SEC. August 2015 turned out to be very busy indeed for the agency, which...more

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