Consent order

Multi-billion dollar federal savings bank

Our attorneys represented a multi-billion dollar federal saving bank in the negotiation of an OCC-issued consent order to address alleged non-compliance with the Bank Secrecy Act and related anti-money laundering regulations.  As a result of our representation, we successfully negotiated out of the proposed order a number of restrictive terms and provisions required in virtually all BSA/AML-related consent orders issued by the OCC, including no requirement to perform an expensive and resource intensive "transactional look-back" review by a third party, and no requirement to perform a comprehensive and costly third-party audit.   In addition, we successfully negotiated a resolution with the OCC for no civil money penalties to be assessed for the alleged regulatory non-compliance.

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