March 14, 2019 | New York Law Journal
Dual Uses—Can the MUFG Consent Order Vindicate the OCC's License Process?The Feb. 21, 2019 OCC Consent Order with MUFG branch banks had two purposes. The commonplace one was to resolve a looming cease and desist action around anti-money laundering issues with the traditional comprehensive regulatory menu of action plans, risk assessments, due diligence prescriptions, transaction monitoring and auditing improvements.
By Robert Axelrod
4 minute read
September 11, 2018 | New York Law Journal
The Oddly Confrontational Strategies in 'Bank of Tokyo-Mitsubishi-Union v. DFS'The position of the DFS is that to allow a bank to jump to another regulator when the state is poised to continue discipline punctuated with prior consent orders is like letting a thief find sanctuary by crossing state lines.
By Robert Axelrod
11 minute read
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