Corruption, Crime & Compliance

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General

16 Oct, 2024

TD Bank’s $3 Billion Settlement: A Review of Regulatory Settlements (Part III of IV)

TD Bank’s $3 billion settlement included coordinated regulatory settlements with the Federal Reserve Board (“Federal Reserve”), The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), and the Office of the Comptroller of the Currency (“OCC”). Each regulator imposed civil penalties and remedial measures. The Federal Reserve fined TD Bank $123.5 million for AML compliance violations. The Federal Reserve also required TD Bank to...
General

16 Oct, 2024

TD Banks’ Pervasive and Systemic Criminal Misconduct (Part II of IV)

“By making its services convenient for criminals, TD Bank became one,” Attorney General Merrick B. Garland. TD Bank joins the list of dysfunctional companies — add them to Wells Fargo, Wirecard, Volkswagen, General Motors, Goldman Sachs, and the hall of fame of financial scandals. TD Bank became a criminal organization, its employees even stated so in email communications, and its leadership operated with a criminal...
General

14 Oct, 2024

TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations (Part I of IV)

In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion settlement with TD Bank companies to resolve systemic and pervasive Bank Secrecy Act (“BSA”) and money laundering violations. In addition to the financial settlement, TD Bank US Holding Company (TDBUSH) (together with TDBNA,...
Podcasts

13 Oct, 2024

Episode 340 — DOJ Updates Evaluation of Corporate Compliance Programs

The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs. As everyone knows, the Justice Department’s guidance carries talismanic significance — it is an important document that provides important direction on the design and implementation of an effective compliance program. DOJ understands the importance of this document. In recognition of evolving technology and compliance program innovations, DOJ updated its guidance to...
General

10 Oct, 2024

UK’s OFSI Imposes £15,000 Penalty on Property Management Company for Sanctions Violations

In late August 2024, the UK’s Office of Financial Sanctions Implementation (“OFSI”), a department within HM Treasury, imposed a monetary penalty of £15,000 on Integral Concierge Services Limited (“ICSL”)—a UK-based property management and concierge company—for serial breaches of the Russia (Sanctions) (EU Exit) Regulations 2019. The enforcement action followed an extensive investigation that uncovered ICSL’s involvement in facilitating payments linked to a designated individual subject...

16 Oct, 2024

TD Bank’s $3 Billion Settlement: A Review of Regulatory Settlements (Part III of IV)

TD Bank’s $3 billion settlement included coordinated regulatory settlements with the Federal Reserve Board (“Federal Reserve”), The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), and the Office of the Comptroller of the Currency (“OCC”). Each regulator imposed civil penalties and remedial measures. The Federal Reserve fined TD Bank $123.5 million for AML compliance violations. The Federal Reserve also required TD Bank to...

General

16 Oct, 2024

TD Banks’ Pervasive and Systemic Criminal Misconduct (Part II of IV)

“By making its services convenient for criminals, TD Bank became one,” Attorney General Merrick B. Garland. TD Bank joins the list of dysfunctional companies — add them to Wells Fargo, Wirecard, Volkswagen, General Motors, Goldman Sachs, and the hall of fame of financial scandals. TD Bank became a criminal organization, its employees even stated so in email communications, and its leadership operated with a criminal...

General

14 Oct, 2024

TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations (Part I of IV)

In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion settlement with TD Bank companies to resolve systemic and pervasive Bank Secrecy Act (“BSA”) and money laundering violations. In addition to the financial settlement, TD Bank US Holding Company (TDBUSH) (together with TDBNA,...

Podcasts

13 Oct, 2024

Episode 340 — DOJ Updates Evaluation of Corporate Compliance Programs

The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs. As everyone knows, the Justice Department’s guidance carries talismanic significance — it is an important document that provides important direction on the design and implementation of an effective compliance program. DOJ understands the importance of this document. In recognition of evolving technology and compliance program innovations, DOJ updated its guidance to...

General

10 Oct, 2024

UK’s OFSI Imposes £15,000 Penalty on Property Management Company for Sanctions Violations

In late August 2024, the UK’s Office of Financial Sanctions Implementation (“OFSI”), a department within HM Treasury, imposed a monetary penalty of £15,000 on Integral Concierge Services Limited (“ICSL”)—a UK-based property management and concierge company—for serial breaches of the Russia (Sanctions) (EU Exit) Regulations 2019. The enforcement action followed an extensive investigation that uncovered ICSL’s involvement in facilitating payments linked to a designated individual subject...

General

8 Oct, 2024

BIS Reaches $151,875 Settlement with Quantum Corporation Over Violations of the EAR’s Antiboycott Provisions

On September 30, 2024, Quantum Corporation—a U.S.-based technology company— reached a settlement with the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) to resolve 45 separate violations of the antiboycott provisions of the Export Administration Regulations (“EAR”). The antiboycott provisions of the EAR are a critical component of U.S. export control regulations designed to prevent U.S. businesses from participating in or supporting foreign...

General

7 Oct, 2024

DOJ Charges Visa with Monopolization and Exclusionary Conduct in the Debit Card Market

The Justice Department’s Antitrust Division has been aggressively pursuing civil enforcement actions. While criminal enforcement of antitrust laws has been depressed, DOJ has found success in pursuing civil and merger enforcement. DOJ recently won a significant victory against Google for its monopolization of the search market. DOJ has now turned its attention outside of technology markets by filing suit against Visa for its dominance of...

Podcasts

6 Oct, 2024

Episode 339 — The Four Sanctions Cases that Everyone Should Know

The Justice Department has repeated on several occasions that it intends to aggressively prosecute corporations for sanctions and export controls violations. The “New FCPA” is how the Justice Department characterizes its plan. To execute the strategy, DOJ has assigned 25 new prosecutors. This is the most important fact — unleashing 25 new prosecutors with the goal of bringing criminal cases against corporations and individuals will...

General

2 Oct, 2024

Commerce Department Updated its Voluntary Self-Disclosure Policy for Export Controls Violations

The Commerce Department’s Bureau of Industry and Security (“DOC-BIS”) is adopting procedures to generate voluntary self-disclosures for violations of export controls laws. Companies have to weigh carefully the risks when deciding whether to make such a disclosure. The Justice Department and DOC-BIS are building joint prosecutions — criminal and civil — against companies for export control violations. This new era is coming and companies have...

General

1 Oct, 2024

DOJ Updates Evaluation of Corporate Compliance Programs

The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs. As everyone knows, the Justice Department’s guidance carries talismanic significance — it is an important document that provides valuable direction on the design and implementation of an effective compliance program. DOJ understands the importance of this document. In recognition of evolving technology and compliance program innovations, DOJ updated its guidance to...

Featured Articles:

TD Bank’s $3 Billion Settlement: A Review of Regulatory Settlements (Part III of IV)

TD Banks’ Pervasive and Systemic Criminal Misconduct (Part II of IV)

TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations (Part I of IV)

Episode 340 — DOJ Updates Evaluation of Corporate Compliance Programs

UK’s OFSI Imposes £15,000 Penalty on Property Management Company for Sanctions Violations

TD Bank’s $3 Billion Settlement: A Review of Regulatory Settlements (Part III of IV)

TD Banks’ Pervasive and Systemic Criminal Misconduct (Part II of IV)

TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations (Part I of IV)

Episode 340 — DOJ Updates Evaluation of Corporate Compliance Programs

UK’s OFSI Imposes £15,000 Penalty on Property Management Company for Sanctions Violations

BIS Reaches $151,875 Settlement with Quantum Corporation Over Violations of the EAR’s Antiboycott Provisions

DOJ Charges Visa with Monopolization and Exclusionary Conduct in the Debit Card Market

Episode 339 — The Four Sanctions Cases that Everyone Should Know

Commerce Department Updated its Voluntary Self-Disclosure Policy for Export Controls Violations

DOJ Updates Evaluation of Corporate Compliance Programs

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