News & Analysis as of

BSA/AML Enforcement Actions

Sheppard Mullin Richter & Hampton LLP

OCC Settles with Bank Over Alleged BSA/AML Violations

On October 16, the OCC announced a formal agreement with a national bank in Florida for alleged unsafe or unsound practices related to board oversight, corporate governance, strategic and capital planning, and compliance with...more

Orrick, Herrington & Sutcliffe LLP

OCC announces enforcement actions for October 2025, including one formal agreement

On October 16, the OCC announced enforcement actions for October, including one new formal agreement and four terminations of prior agreements. The OCC entered into a formal agreement with a national bank in September after...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – October 2025 # 3

Troutman Pepper Locke on

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

Orrick, Herrington & Sutcliffe LLP

OCC releases enforcement actions for September 2025

On September 18, the OCC announced its recent enforcement actions against national banks, federal savings associations, and individuals for September 2025. ...more

Thomas Fox - Compliance Evangelist

All Things Investigations - FinCEN’s Recent Actions: Existential Threat for Financial Institutions in Mexico

Welcome to the Hughes Hubbard Anti-Corruption & Internal Investigations Practice Group’s podcast, All Things Investigation. In this podcast, host Tom Fox welcomes back Jeremy Paner and Diego Durán de la Vega to discuss recent...more

Sheppard Mullin Richter & Hampton LLP

OCC Terminates 2022 Consent Order Against National Bank

On August 18, the OCC terminated its 2022 consent order against a national bank. The order was issued under the Bank Secrecy Act and related anti-money laundering regulations, and required the bank to implement corrective...more

Orrick, Herrington & Sutcliffe LLP

OCC terminates 2022 consent order against federally chartered digital asset bank

On August 18, the OCC terminated its 2022 consent order against a federally chartered bank specializing in digital assets. The OCC, in support of its decision, cited the safety and soundness of the bank and its compliance...more

Orrick, Herrington & Sutcliffe LLP

FINRA fines broker-dealer $500K for failure to file suspicious activity reports

On August 22, FINRA accepted a Letter of Acceptance, Waiver, and Consent (AWC) from a broker-dealer member firm regarding its alleged failure to establish and implement policies and procedures designed to detect suspicious...more

Orrick, Herrington & Sutcliffe LLP

California and other state regulators fine money transmitter $4.2M for BSA/AML violations

On July 9, the California DFPI, alone and joining five other state financial regulatory agencies, announced a multistate enforcement action resulting in a $4.2 million penalty against a licensed money transmitter for alleged...more

Troutman Pepper Locke

OCC Patriot Bank Order Spotlights AML Issues For Managers

Troutman Pepper Locke on

On Jan. 14, Patriot Bank, based in Stamford, Connecticut, entered into an agreement with the Office of the Comptroller of the Currency to address and rectify several alleged unsafe or unsound practices and violations of law....more

Troutman Pepper Locke

Recent SEC AML Enforcement Actions’ Impact on Compliance Efforts in the Cannabis Sector

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Investing in the cannabis industry is not without its risks, given the evolving regulatory landscape and the varying state and federal statuses of the product itself. The Financial Crimes Enforcement Network (FinCEN) has...more

Fenwick & West LLP

Bank-Fintech Partnerships Under Scrutiny: What Fintechs Need to Know About AML Expectations

Fenwick & West LLP on

Bank-fintech partnerships have transformed the financial services landscape, creating new opportunities and challenges for traditional banking institutions and innovative technology companies alike. In a typical arrangement,...more

Gordon Rees Scully Mansukhani

Recent SEC AML Enforcement Against Securities Firms Engaged in Cannabis Sector

The evolving regulatory landscape for marijuana-related businesses poses unique compliance challenges for firms in the securities industry. The Financial Crimes Enforcement Network (“FinCEN”) continues to enforce its 2014...more

Ankura

Challenges in Data Sharing between Banking Partners

Ankura on

Life in the United States and most modern industrialized countries is driven primarily by data. Google alone processes 20 Petabytes of data every day (1 petabyte = 1 million gigabytes. Economies are built on data; marketing...more

Hudson Cook, LLP

State Watch: Consumer Protection Enforcement Update

Hudson Cook, LLP on

While uncertainty continued to loom over the CFPB, the states did not take a spring break. Instead, we saw an eye-popping settlement from NY DFS involving BSA/AML claims. And both republican and democratic AGs continued to...more

Carlton Fields

Recent SEC AML Enforcement Actions and Likely Continued AML Emphasis Under New Administration

Carlton Fields on

Registered investment advisers have until January 1, 2026, to comply with the anti-money laundering (AML) compliance provisions of the Bank Secrecy Act (BSA). However, the SEC has recently charged two investment advisers with...more

Troutman Pepper Locke

Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast

Troutman Pepper Locke on

In this episode of Payments Pros, host Carlin McCrory discusses a recent consent order between Patriot Bank and the Office of the Comptroller of the Currency (OCC) following a $27 million loss. The order addresses unsafe...more

WilmerHale

SEC Shouldn't Complicate Broker-Dealers' AML Compliance

WilmerHale on

The U.S. Securities and Exchange Commission's recent anti-money laundering enforcement actions reflect a number of trends and developments, but one positive and one negative trend stand out. Originally published in Law360...more

Orrick, Herrington & Sutcliffe LLP

OCC releases March 2025 enforcement actions

On March 20, the OCC released a list of recent enforcement actions taken against national banks, federal savings associations, and individuals affiliated with supervised banks. Among the actions taken, the OCC issued a cease...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 59: Don’t Sleep on the States: Financial Regulatory, Compliance & Enforcement Trends

RegFi co-hosts Jerry Buckley and Sherry Safchuk welcome fellow Orrick partner Katy Ryan to discuss the state financial regulatory landscape. Katy provides an overview of how federal agencies and states interact in our...more

Orrick, Herrington & Sutcliffe LLP

FDIC declines to defend administrative law judges in bank litigation, bank responds

On February 24, the FDIC informed the U.S. District Court for the District of Kansas that it would no longer defend its use of administrative law judges (ALJs). As previously covered by InfoBytes, DOJ declared the multiple...more

Troutman Pepper Locke

Patriot Bank and OCC Sign Agreement to Strengthen Oversight and Payment Activities

Troutman Pepper Locke on

On January 14, Patriot Bank, N.A. entered into an agreement with the Office of the Comptroller of the Currency (OCC) to address and rectify several unsafe or unsound practices and violations of law. This agreement follows the...more

Ballard Spahr LLP

Patriot Bank Enters Agreement with OCC to Address Regulatory Concerns

Ballard Spahr LLP on

On February 20, 2025, the Office of the Comptroller of the Currency (“OCC”) announced that they had entered into a formal agreement with Patriot Bank, National Association (“Patriot Bank”), following a comprehensive...more

Troutman Pepper Locke

Key Considerations After DOJ Announces Shifting Enforcement Priorities

Troutman Pepper Locke on

On February 5, U.S. Attorney General (AG) Pam Bondi issued 14 memoranda to Department of Justice (DOJ) employees framing the DOJ's current policies and enforcement priorities. These shifting enforcement priorities are aligned...more

K&L Gates LLP

Lessons From 2024 Anti-Money Laundering Enforcement Actions

K&L Gates LLP on

In 2024, FinCEN and the federal bank regulators announced more than three dozen enforcement actions against banks and individuals arising from alleged Bank Secrecy Act (BSA), anti-money laundering (AML), and countering the...more

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