The New Normal: Taking Responsibility for Your Vendors
FinCEN’s new Enforcement Division, which was created in June of 2013, is already making its mark in the financial enforcement world.
Federal regulators are focusing on compliance with Bank Secrecy Act (“BSA”) and...more
This week, federal authorities announced the assessment of civil money penalties against two financial institutions for alleged Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance failures. In the first action, FinCEN...more
The OCC entered into a consent order with a small, New Jersey-based bank with approximately $118 million in total assets for violations of the Bank Secrecy Act (the “BSA”). The OCC assessed a civil money penalty (“CMP”)...more
Originally published in BNA’s Banking Report, 100 BBR 617 on 04/02/2013.
Overall Trends & Outlook -
In 2012, the federal banking agencies, including the Federal Deposit Insurance Corporation (‘‘FDIC’’), Office...more
On December 11, a major international bank holding company announced agreements with U.S. law enforcement authorities and federal bank regulators to end investigations into alleged inadequate compliance with anti-money...more
Following on the heels of the $15 million settlement against First Bank of Delaware for significant Bank Secrecy Act/Anti-Money Laundering violations (as we reported on here), the Treasury Department and three federal...more
Last month, the U.S. Supreme Court denied the Petition for a Writ of Certiorari in Cummings v. Doughty, thereby leaving open a split among circuit courts regarding the scope of the immunity financial institutions that file...more