News & Analysis as of

Office of the Comptroller of the Currency FinCEN Civil Monetary Penalty

King & Spalding

State Attorneys General Poised to Elevate Regulatory Scrutiny of Digital Asset Businesses

King & Spalding on

The Attorney General Alliance (“AGA”) recently issued a collaborative White Paper that signals heightened scrutiny of digital asset businesses by state Attorneys General in coming years. Recognizing that it is “no longer...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

Skadden, Arps, Slate, Meagher & Flom LLP

The Distributed Ledger: Blockchain, Digital Assets and Smart Contracts - October 2020

Recent and significant regulatory and legislative events in the digital asset space demonstrate the evolving and expanding approach by U.S. and international regulators to the burgeoning digital asset markets. These...more

Goodwin

SEC Adopts Rule Providing New Regulatory Framework For Fund-Of-Funds

Goodwin on

In the News. The Securities and Exchange Commission (SEC) announced that it adopted Rule 12d1-4 under the Investment Company Act of 1940 (the 1940 Act), providing a new regulatory framework for fund-of-funds and final...more

Kelley Drye & Warren LLP

Former US Bank Exec Held Individually Liable for Anti-Money Laundering

Compliance Failures - On March 4, 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a consent order assessing a $450,000 civil money penalty against Michael LaFontaine, former Chief...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

White & Case LLP on

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

Akin Gump Strauss Hauer & Feld LLP

FinCEN Enforcement Action Highlights AML Compliance Program Failures and Conflicts of Interest for High-Risk MSB Customers

On February 27, 2017, FinCEN announced a $7 million civil monetary penalty against Merchants for willful violations of the BSA. Additionally, the Office of the Comptroller of the Currency (OCC), Merchants’ federal functional...more

Morrison & Foerster LLP

Financial Services Report, Fall 2016

Editor’s Note - So much for summer! The weather is cooling, the kids are back to school, and we better not see you wearing white so long after Labor Day! For those of you having a little trouble getting back in the...more

Manatt, Phelps & Phillips, LLP

$6.5M Fine for Persistent BSA/AML Failures: Prelude to OCC's Announcement of Tougher Enforcement Environment

Why it matters - A $6.5 million civil money penalty imposed against a $1.57 billion Florida bank for persistent anti-money laundering (AML) and Bank Secrecy Act (BSA) deficiencies provided an appropriate back drop for...more

Goodwin

OCC and FinCEN Take Enforcement Actions and Assess Civil Money Penalty Against Small Bank for BSA/AML Violations

Goodwin on

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

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