News & Analysis as of

Money Laundering Office of the Comptroller of the Currency BSA/AML

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

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

Ballard Spahr LLP

Changes to Data Collection for OCC’s Money Laundering Risk System

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On September 8, the Office of the Comptroller of the Currency (“OCC”) published an extension of its notice and request for comment (the “Notice”) in the Federal Register regarding changes to the OCC’s Money Laundering Risk...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

Foodman CPAs & Advisors

Are Banks Implementing BSA Risk Based Adjustments related to COVID-19 circumstances?

The Office of the Comptroller of the Currency (OCC) Semiannual Risk Perspective Report highlights how the Covid-19 Pandemic has elevated  operational risks for banks as they are challenged with the implementation of new...more

Ballard Spahr LLP

OCC Action Highlights Increased Accountability Facing Boards Of Directors

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Regulatory Examination and Related Enforcement Also Highlights Perceived Risks of Banking Crypto Clients - The Department of the Treasury’s Office of the Comptroller of the Currency (“OCC”) recently issued a Consent Order...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

The OCC Releases Fiscal Year 2020 Bank Supervision Operation Plan

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On October 1st, the Office of the Comptroller of the Currency (OCC) published the Fiscal Year 2020 Bank Supervision Operating Plan (“FY 2020 Plan”). ...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

Ballard Spahr LLP

Senate Committee Hears from OCC, FinCEN and FBI on Risks Posed by Anonymous Corporate Structures

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Testimony Supports Bill Requiring States to Collect Beneficial Ownership Information at Entity Formation - As we have blogged, the proposed Corporate Transparency Act of 2019 (the “Act”) seeks to ensure that persons who...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

Ballard Spahr LLP

OCC Semiannual Risk Perspective Highlights Cybersecurity, Fraud, Money Laundering Concerns

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Last week, the Office of the Comptroller of the Currency (“OCC”) published the Spring 2018 Semiannual Risk Perspective (the “Report”), which uses up-to-date data to identify risks to U.S. banks and measure their compliance...more

Ballard Spahr LLP

OCC Report: Same Threats, Different Season

Ballard Spahr LLP on

OCC Identifies AML/BSA and Cyber Threats as Elevated Risks Facing Banks - Last week, the Office of the Comptroller of the Currency (“OCC”) published the Spring 2018 Semiannual Risk Perspective (the “Report”), which uses...more

K&L Gates LLP

Obstructing Bank Examinations Is a Costly Crime

K&L Gates LLP on

Recently, an American bank entered into a deferred prosecution agreement requiring it to pay over US$610 million in penalties. The plea agreement was based on “impos[ing] hard caps on the number of transactions subject to AML...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

Orrick, Herrington & Sutcliffe LLP

Comptroller of the Currency Tom Curry Discusses Fintech Charters

In his remarks at the LendIt Conference in New York, Comptroller of the Currency Tom Curry discussed the special purpose national bank charters to be granted by the OCC to fintech companies and addressed the various...more

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