News & Analysis as of

Cease and Desist Orders Banking Sector

Orrick, Herrington & Sutcliffe LLP

OCC releases enforcement actions for November 2024

On November 21, the OCC released a list of recent enforcement actions against national banks, federal savings associations, institution-affiliated parties (IAPs, or individuals associated with these entities). The OCC issued...more

Orrick, Herrington & Sutcliffe LLP

Fed issues two cease and desist orders against banks

On November 13, the Fed issued a cease and desist order against a state-chartered bank (respondent), due to alleged deficiencies in its operations and risk management practices related to Bank Secrecy Act (BSA) and anti-money...more

Sheppard Mullin Richter & Hampton LLP

Fed Brings Enforcement Action Against Wyoming Bank Holding Company Over “Fintech Business Strategy”

On March 28, the Federal Reserve (Fed) issued a cease-and-desist order to a Wyoming-based bank holding company, citing deficiencies identified in a September 2023 inspection related to its “fintech business strategy, board...more

Bradley Arant Boult Cummings LLP

Connecticut Banking Commissioner Order Highlights Risks Associated with Call Center Mortgage Loan Origination and Employee Social...

On January 4, 2024, Connecticut Banking Commissioner Jorge L. Perez issued a temporary order to cease and desist against LoanSnap, Inc., ordering LoanSnap to cease and desist certain activities and notifying LoanSnap that its...more

Ballard Spahr LLP

FDIC issues cease and desist letters alleging false or misleading representations about deposit insurance on crypto-related...

Ballard Spahr LLP on

On August 19, 2022, the FDIC issued cease and desist letters to five crypto companies, alleging they made false and misleading statements about FDIC deposit insurance and demanding immediate corrective action. The five...more

Ballard Spahr LLP

FDIC Updates Enforcement Manual for Cease-and-Desist Actions

Ballard Spahr LLP on

On July 25, 2022, the FDIC issued Financial Institution Letter (FIL)-34-2022 announcing updates to Chapters 1 and 4 of its Formal and Informal Enforcement Actions Manual (Manual). The Manual includes updates to the minimum...more

Ballard Spahr LLP

Federal Banking Agencies Issue Joint Statement On Enforcement of BSA/AML Requirements; FinCEN Follows With Its Own

Ballard Spahr LLP on

Regulators Provide Greater Transparency into BSA/AML Enforcement Process - On August 13, 2020 the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the...more

Troutman Pepper Locke

Lifting of Longstanding OCC Consent Order May Signal Improved Environment for Bank Partnerships

Troutman Pepper Locke on

On February 14, the Office of the Comptroller of the Currency (OCC) terminated a longstanding cease-and-desist order against payday lender ACE Cash Express, Inc. ...more

Sullivan & Worcester

Bank Corporate Governance—Fed lowers Boom on Wells’ Directors

Sullivan & Worcester on

On February 2, 2018, the Fed announced that it issued a consent Cease and Desist order with Wells Fargo—the bank holding company. The Fed’s press release noted that Wells is replacing 4 directors within this year (out of 17...more

Moore & Van Allen PLLC

Anti-Money Laundering and Bank Secrecy Act Update

Moore & Van Allen PLLC on

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

The Volkov Law Group

Lessons Learned From FCPA Enforcement Against JP Morgan for Sons and Daughters Referral Program

The Volkov Law Group on

Last week, the Justice Department and the SEC finally brought to a close the Sons and Daughters or Princelings investigation. Pending investigations against four other companies still remain to be resolved....more

Thomas Fox - Compliance Evangelist

JPMorgan Sons and Daughters FCPA Enforcement Action, Part II

Today I will consider the superior result achieved by JPM in its FCPA resolution. Not only did it receive a 25% discount off the bottom of the US Sentencing Guidelines fine range but it received a NPA and not even a Deferred...more

Thomas Fox - Compliance Evangelist

Three Key Questions to Ask in Hiring of Family Members of Foreign Officials

One of the top academic commentators in the anti-corruption space is Matthew C. Stephenson, co-founder of the Global Anticorruption Blog. I was intrigued by Stephenson’s piece, entitled “Does an FCPA Violation Require a Quid...more

Dorsey & Whitney LLP

UBS Settles Structured Note Case with SEC

Dorsey & Whitney LLP on

The Commission brought its first case tied to inadequate disclosure regarding structured notes. The complex instruments, a debt security linked to a derivative tied to the performance of other products, are frequently...more

Thomas Fox - Compliance Evangelist

Reflections on the Hitachi FCPA Enforcement Action

Earlier this week, the Securities and Exchange Commission (SEC) announced resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Hitachi Ltd (Hitachi). There were several interesting aspects to...more

Thomas Fox - Compliance Evangelist

BNY Mellon and Lessons Learned In Hiring Family Members – Part II

In yesterday’s post I reviewed the Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action involving the Bank of New York Mellon Corporation (BNY Mellon) around its hiring of sons and...more

Dorsey & Whitney LLP

SEC- BNY Mellon Settle FCPA Charges Tied To Hiring Relatives of Officials

Dorsey & Whitney LLP on

The SEC has been investigating sovereign wealth funds and issues relating to the hiring of friends and family of foreign officials for some time. Now it has filed a settled action centered on both of those issues which...more

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