News & Analysis as of

Financial Institutions Civil Monetary Penalty

Ogletree, Deakins, Nash, Smoak & Stewart,...

Whistleblower Update: SEC, DOJ Still Focusing on Employment Agreements and Written Policies, Off-Channel Communications

The U.S. Securities and Exchange Commission (SEC) brought more actions targeting regulated entities for recordkeeping violations related to employees using noncompany communications platforms, and both the SEC and the U.S....more

Mayer Brown

UK Government Launches Office of Trade Sanctions Implementation to Enforce UK Trade Sanctions

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On 12 September 2024, the UK Government published the regulatory framework providing the scope and powers of the Office of Trade Sanctions Implementation (OTSI), the authority responsible for the implementation and...more

DarrowEverett LLP

Actions vs. J.P. Morgan, Monolith Serve as SEC Compliance Check Reminders

DarrowEverett LLP on

The Securities and Exchange Commission (SEC) recently settled charges against J.P. Morgan Securities LLC (JPMS) for impeding hundreds of advisory clients and brokerage customers from reporting potential securities law...more

K&L Gates LLP

SEC Enforcement Targets Anti-Whistleblower Practices in Financial Firm's Release Agreements With Retail Clients

K&L Gates LLP on

As the year gets underway, the Securities and Exchange Commission (SEC or Commission) is continuing its ongoing enforcement efforts to target anti-whistleblower practices by pursuing a broader range of entities and...more

King & Spalding

ICBC Settles AML/BSA and CSI Matters with DFS, Fed: Three Take-Aways

King & Spalding on

AML Developments - What You Need to Know - Earlier this month, the New York State Department of Financial Services (“DFS”) and the Federal Reserve Board of Governors (“FRB”) announced settlements with the Industrial and...more

Davis Wright Tremaine LLP

CFTC Division of Enforcement, FY 2023: A Year in Review and Looking Ahead

On November 7, 2023, the Division of Enforcement ("Division") of the United States Commodity Futures Trading Commission ("CFTC") released its annual report of the results of its enforcement efforts, announcing that it had...more

Dunlap Bennett & Ludwig PLLC

Corporate Transparency Act Requires Small Businesses To Disclose Beneficial Ownership Information Beginning In 2024

In January of 2021, Congress passed the Corporate Transparency Act of 2019 (the “CTA”) as part of the 2021 Defense Bill. Initially introduced in 2019, the CTA requires private companies to disclose their “Beneficial Owners”...more

A&O Shearman

UK Russia sanctions: back in the spotlight

A&O Shearman on

Sanctions and the systems and controls companies have in place to comply with them seem to be back in the spotlight. In addition to guidance recently published by the UK Financial Conduct Authority, a number of recent...more

Pillsbury Winthrop Shaw Pittman LLP

The Corporate Transparency Act: Beneficial Ownership Information Reporting Checklist

The Corporate Transparency Act requires a broad range of entities to file a report with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) identifying those who own, control and formed the...more

Sheppard Mullin Richter & Hampton LLP

FDIC Settles with Bank for Repeat RESPA Violations, Doubling Previous Fine

The FDIC recently announced a consent order with an Oregon regional bank for violations of Section 8 of RESPA, the FTC Act, and the FRCA, resulting in a civil monetary penalty totaling $425,000. After conducting its...more

Orrick, Herrington & Sutcliffe LLP

FDIC issues December enforcement actions

On January 27, the FDIC released a list of administrative enforcement actions taken against banks and individuals in December. The FDIC made public nine orders, including “one order to pay civil money penalty, two consent...more

Goodwin

FinCEN Proposes Form of Report to Collect Beneficial Ownership Information and Application to Obtain FinCEN Identifiers

Goodwin on

Regulatory Developments - FinCEN Proposes Form of Report to Collect Beneficial Ownership Information and Application to Obtain FinCEN Identifiers - On January 17, FinCEN proposed a form of report to collect beneficial...more

Hudson Cook, LLP

CFPB Bites of the Month - January 2023 - May Old Compliance Acquaintances be Forgot

Hudson Cook, LLP on

In this month's article, we share some of our top "bites" for the prior month covered during the January 18, 2023, webinar. Bite # 8: The CFPB Publishes Civil Penalty Inflation Adjustments Rule in Federal Register - ...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update – FinCEN Issues Notice of Proposed Rulemaking

On December 15, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (the “NPRM”) that would implement provisions of the Corporate Transparency Act (the “CTA”) regarding access to...more

Orrick, Herrington & Sutcliffe LLP

FinCEN issues final rule replacing obsolete BSA civil penalty regulations

On December 23, the Financial Crimes Enforcement Network (FinCEN) published a final rule amending the Bank Secrecy Act civil penalty regulations concerning requirements for reporting foreign financial accounts and...more

Sheppard Mullin Richter & Hampton LLP

OCC Revises Policies and Procedures for Civil Money Penalties

On November 29, the OCC released a revised Policies and Procedures Manual relating to the assessment of civil money penalties (“CMP Matrix”), which will be effective as of January 1, 2023. The CMP Matrix is a reference guide...more

Goodwin

SEC and CFTC Send Powerful Message With $2 Billion in Fines Related to Social Media and Text Recordkeeping Lapses

Goodwin on

​​​​​​​The SEC and CFTC recently charged 11 large financial institutions and their affiliates for failing to collect, monitor, and preserve communications over WhatsApp and other messaging services. These settlements follow a...more

Robinson & Cole LLP

With $1.1 Billion Penalty Deal, SEC Joins DOJ in Firing Warning Shot at Financial Services Industry About Outdated Employee...

Robinson & Cole LLP on

Last week, the United States Securities and Exchange Commission (SEC) fined 16 Wall Street firms a total of $1.1 billion for recordkeeping violations based on the failure to maintain employees’ electronic communications, such...more

Cadwalader, Wickersham & Taft LLP

Eleven Financial Institutions Pay $700 Million to Settle Recordkeeping and Supervision Violations Related to Off-Channel Business...

On September 27, the Commodity Futures Trading Commission (“CFTC”) issued orders to settle charges against 11 major U.S. and international financial institutions and their swap dealer (“SD”) and futures commission merchant...more

Nutter McClennen & Fish LLP

Nutter Bank Report: September 2022

Headlines: ..OCC Publishes Security Standards for Video Teleconferencing With Agency Staff ..CFPB Imposes Civil Penalty and Customer Refunds for Authorized-Positive Overdraft Fees ..Treasury Department Recommends...more

Bass, Berry & Sims PLC

Government Announces First FCA Settlement with PPP Lender

Bass, Berry & Sims PLC on

The Department of Justice (DOJ) announced on September 12, the first-ever False Claims Act (FCA) settlement with a Paycheck Protection Program (PPP) lender. Prosperity Bank, a Texas-based regional bank, agreed to pay...more

Goodwin

FinCEN Proposes Rule for SARs Sharing Pilot Program

Goodwin on

In This Issue. The Financial Crimes Enforcement Network (FinCEN) issued a proposed rule about the establishment of a limited-duration pilot program for sharing suspicious activity reports (SARs); FinCEN published the final...more

Winthrop & Weinstine, P.A.

CFPB Renews Focus on Bank Overdraft Fees, Likely Increasing Litigation Risk

The hottest topic in banking this month is overdraft fees. On December 1, 2021, Capital One bank announced it would be eliminating all overdraft fees for consumer accounts, ending a practice that once netted the bank over...more

Steptoe & Johnson PLLC

The Corporate Transparency Act

Steptoe & Johnson PLLC on

The Corporate Transparency Act (CTA), included as an amendment to the Anti-Money Laundering Act of 2020, was passed by Congress this year as an effort to make it more difficult to commit “shell company” money laundering, tax...more

Perkins Coie

Fintech Legal Report - September 2021 #2

Perkins Coie on

House Financial Services Committee Discusses Consumer Rights to Access Personal Financial Data - On September 21, 2021, the House Committee of Financial Services Task Force on Financial Technology held a hybrid hearing...more

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