OVERVIEW

Sullivan & Cromwell’s Banking Enforcement Actions Tracker—or BEAT—is a web-based tool that aggregates and displays data pertaining to significant enforcement actions from January 1, 2008 to the present against banking organizations by the federal banking agencies, the New York State Department of Financial Services, and select other federal and state agencies.  In addition, the BEAT displays data regarding significant civil and criminal actions taken by the Department of Justice against banking organizations since January 1, 2001.  The BEAT permits users to directly search and sort the actions based on key factors of interest and using search terms, and provides important summary information about each action, thus making unnecessary the labor-intensive manual searches and reviews that, until now, have been required to compile meaningful information about enforcement actions.

There are two versions of the BEAT: a limited version, which is publicly available, and a full version, which is available to clients of Sullivan & Cromwell and offers additional features as outlined below:



The BEAT’s development and broad availability demonstrate Sullivan & Cromwell’s ongoing commitment to adding value for our clients with banking regulatory needs.
 
Sullivan & Cromwell intends to regularly update the BEAT and welcomes feedback on the tool. Clients interested in access to the full version are encouraged to contact any Sullivan & Cromwell partner you work with.  

Last Updated: February 24, 2020

Disclaimer Notice

If you registered a BEAT account before January 1, 2018, please click “Forgot Your Password?” below and update your password.

LOG IN


RESULTS (15 of 400+ | Log In to See More)
SORT BY:

Viewing limited results below. Registered users should log in to access the full database. If you are a Sullivan & Cromwell client and wish to request login credentials, please click here.
761
Citibank N.A
January 16, 2020
OCC
Consent Order (CMP)
$17,998,510
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
12 C.F.R. § 22.7(a) (Notice and Purchase of Flood Insurance Coverage)
National Flood Insurance Act of 1968 and the Flood Disaster Protection Act of 1973, 42 U.S.C. § 4012a(f)(2)
DOWNLOAD
760
Union Bancaire Privée
January 2, 2020
DOJ
Addendum to an NPA
$14,000,000
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
759
Société Générale S.A. and Société Générale New York Branch
December 17, 2019
FRB
Written Agreement
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
12 C.F.R. § 223 (Transactions between Member Banks and their Affiliates)
12 U.S.C. § 371c (Banking Affiliates)
12 U.S.C. § 371c-1 (Restrictions on transactions with affiliates)
DOWNLOAD
758
SunTrust Bank
November 19, 2019
FRB
Consent Order (C&D)
Consumer Compliance
No Yes No
LOOKBACK: No
REDRESS: Yes
RELEASE: No
Violations Cited:
15 U.S.C. § 45(a)(1) (Unfair or Deceptive Acts and Practices/UDAP)
DOWNLOAD
757
HomeStreet Bank
November 6, 2019
FDIC
Consent Order (CMP)
$1,350,000
Mortgages
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
Real Estate Settlement Procedures Act, 12 U.S.C. § 2607 (prohibition against kickbacks and unearned fees)
Regulation X, 12 C.F.R. § 1024
DOWNLOAD
756
Citibank N.A
October 11, 2019
OCC
Consent Order (CMP)
$30,000,000
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
12 C.F.R. § 34.82 (OREO Holding Period)
12 U.S.C. § 29 (Possession of Real Estate by a National Bank)
DOWNLOAD
755
MUFG Union Bank, N.A.
July 29, 2019
OCC
Consent Order (CMP)
$109,667
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
12 C.F.R. § 22.3(a) (Requirement to Purchase Flood Insurance)
DOWNLOAD
754
Freedom Debt Relief, LLC
July 9, 2019
CFPB
Final Judgement and Order
$5,000,000
Consumer Compliance
Yes Yes Yes
LOOKBACK: Yes
REDRESS: Yes
RELEASE: Yes
Violations Cited:
12 U.S.C. §§ 5531, 5536 (Unfair, Deceptive or Abusive Acts and Practices/UDAAP)
Telemarketing and Consumer Fraud and Abuse Prevention Act 15 U.S.C. §§ 6102(c), 6105(d)
Telemarketing Sales Rule, 16 C.F.R. § 310
DOWNLOAD
753
The Bank of Tokyo-Mitsubishi UFJ, Ltd.
June 24, 2019
NYDFS
Settlement Agreement
$33,000,000
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
Unspecified
DOWNLOAD
751
State Street Bank and Trust Company
May 28, 2019
OFAC
Finding of Violation
Sanctions
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
Iranian Transactions Regulations, 31 C.F.R. § 560
DOWNLOAD
749
Sumitomo Mitsui Banking Corporation; Sumitomo Mitsui Banking Corporation New York Branch
April 23, 2019
FRB
Written Agreement
BSA/AML
Yes No No
LOOKBACK: Yes
REDRESS: No
RELEASE: No
Violations Cited:
12 C.F.R. § 211.24(f) (BSA Program)
12 C.F.R. § 211.24(j) (BSA Program)
31 C.F.R. Chapter V (OFAC Regulations)
31 C.F.R. Chapter X (FinCEN Regulations)
Bank Secrecy Act, 31 U.S.C. §§ 5311 et seq.
DOWNLOAD
745
UniCredit Bank AG
April 15, 2019
OFAC
Settlement Agreement
$553,380,758
Sanctions
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
31 C.F.R. § 542 (Syrian Sanctions Regulations)
31 C.F.R. § 544 (Weapons of Mass Destruction Proliferators Sanctions Regulations)
31 C.F.R. § 570.201 (Libyan Sanctions Regulations)
31 C.F.R. § 594.201 (Prohibited transactions involving blocked property)
Burmese Sanctions Regulations, 31 C.F.R. § 537
Cuban Assets Control Regulations, 31 C.F.R. § 515
Iranian Transactions Regulations, 31 C.F.R. § 560
Sudanese Sanctions Regulations, 31 C.F.R. § 538
DOWNLOAD
747
UniCredit Bank Austria AG
April 15, 2019
OFAC
Settlement Agreement
$20,326,340
Sanctions
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
31 C.F.R. § 542 (Syrian Sanctions Regulations)
Burmese Sanctions Regulations, 31 C.F.R. § 537
Cuban Assets Control Regulations, 31 C.F.R. § 515
Iranian Transactions Regulations, 31 C.F.R. § 560
Sudanese Sanctions Regulations, 31 C.F.R. § 538
DOWNLOAD
748
UniCredit S.p.A.
April 15, 2019
OFAC
Settlement Agreement
$37,316,322
Sanctions
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
31 C.F.R. § 542 (Syrian Sanctions Regulations)
Burmese Sanctions Regulations, 31 C.F.R. § 537
Cuban Assets Control Regulations, 31 C.F.R. § 515
Iranian Transactions Regulations, 31 C.F.R. § 560
Sudanese Sanctions Regulations, 31 C.F.R. § 538
DOWNLOAD
750
GE Capital; WMC Mortgage Corporation LLC
April 12, 2019
DOJ (CIV)
Settlement Agreement
$1,500,000,000
FIRREA/Mortgages
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
Financial Institutions Reform, Recovery, and Enforcement Act ("FIRREA"), 12 U.S.C. § 1833a (Civil Penalties)

For this purpose, an action is "significant" if it is either (1) an action against a Global Systemically Important Bank, (2) an action against a banking organization with $50 billion or more in assets, or (3) an action that involves at least one of the following: (a) penalties of $1 million or more; (b) substantial consumer relief requirements; or (c) coordinated or parallel actions by a federal banking agency and at least one other agency.

Prior to October 2011 The New York Department of Financial Services was the New York State Banking Department.

Disclaimer Notice: Banking Enforcement Actions Tracker is an informational product provided by Sullivan & Cromwell LLP and should not be regarded as a substitute for legal advice.