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: May 3, 2021

Disclaimer Notice

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

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801
Capital One, N.A.
January 15, 2021
FinCEN
Consent Order (CMP)
$390,000,000
BSA/AML
Yes No Yes
LOOKBACK: Yes
REDRESS: No
RELEASE: Yes
Violations Cited:
31 C.F.R. § 1010.306 (Filing of Reports)
31 C.F.R. § 1010.310 (Reports of Transactions in Currency)
31 C.F.R. § 1020.210 (BSA Program)
31 U.S.C §§ 5318(a)(2) (AML Program)
31 U.S.C. § 5313 (CTRs)
31 U.S.C. § 5318(g) (SARs)
31 U.S.C. § 5318(h) (BSA Program)
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800
Deutsche Bank Aktiengesellschaft
January 7, 2021
DOJ (CRIM)
Deferred Prosecution Agreement
$87,091,424
Other
No Yes Yes
LOOKBACK: No
REDRESS: Yes
RELEASE: Yes
Violations Cited:
15 U.S.C. § 78m(b)(2)(A), 78m(b)(5), 78ff(a) (Books and Records Provisions of FCPA)
15 U.S.C. § 78m(b)(2)(B), 78m(b)(5), 78ff(a) (Internal Controls Provisions of FCPA)
18 U.S.C. § 1343 (Wire Fraud)
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799
Union de Banques Arabes et Françaises
January 4, 2021
OFAC
Settlement Agreement
$8,572,500
Sanctions
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
Executive Order 13382 (Prohibited Transactions Involving Designated Persons)
Executive Order 13582 (Syria Sanctions)
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798
National Commercial Bank
December 28, 2020
OFAC
Setllement Agreement
$653,347
Sanctions
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
Executive Order 13582 (Syria Sanctions)
Sudanese Sanctions Regulations, 31 C.F.R. § 538
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797
Credit Suisse Group AG; Credit Suisse AG; Credit Suisse Holdings (USA), Inc.; Credit Suisse AG, New York Branch; Federal Reserve Bank of New York; New York State Department of Financial Services
December 22, 2020
FRB
Written Agreement
BSA/AML
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
Unspecified
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794
Discover Bank; The Student Loan Corporation; Discover Products, Inc.
December 21, 2020
CFPB
Consent Order (C&D & CMP)
$35,000,000
Fair Lending
No Yes Yes
LOOKBACK: No
REDRESS: Yes
RELEASE: Yes
Violations Cited:
12 C.F.R. § 1005 (Regulation E of the Electronic Funds Transfer Act)
12 U.S.C. §§ 5531, 5536 (Unfair, Deceptive or Abusive Acts and Practices/UDAAP)
Electronic Fund Transfer Act, 15 U.S.C. §§ 1693 et seq.
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795
Santander Consumer USA Inc.
December 21, 2020
CFPB
Consent Order (C&D & CMP)
$4,750,000
Consumer Compliance
Yes No Yes
LOOKBACK: Yes
REDRESS: No
RELEASE: Yes
Violations Cited:
12 C.F.R. § 1022.42(a) (Policies and Procedures for Furnished Information)
Consumer Financial Protection Act of 2010, 12 U.S.C. § 5536
Fair Credit Reporting Act, 15 U.S.C. §§ 1681 et seq.
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796
Apple Bank for Savings
December 21, 2020
FDIC
Consent Order (CMP)
$12,500,000
BSA/AML
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
12 C.F.R. § 326.8 (BSA Program)
12 C.F.R. § 353.1-353.3 (SARs)
12 U.S.C. § 1818(s) (BSA Program)
12 U.S.C. § 1829(b) (BSA-Recordkeeping)
12 U.S.C. §§ 1951-1959 (BSA-Uninsured Financial Institutions)
31 C.F.R. Chapter X (FinCEN Regulations)
Bank Secrecy Act, 31 U.S.C. §§ 5311 et seq.
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793
JPMorgan Chase Bank, N.A.
November 24, 2020
OCC
Consent Order (CMP)
$250,000,000
Other
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
12 C.F.R. § 9.9 (Audit of Fiduciary Activities)
Unsafe and Unsound Practices
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792
USAA Federal Savings Bank
November 10, 2020
OCC
Consent Order (CMP)
$382,500
Other
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
12 C.F.R. § 22.7(a) (Notice and Purchase of Flood Insurance Coverage)
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789
The Goldman Sachs Group, Inc.
October 22, 2020
FRB
Consent Order (C&D & CMP)
$154,000,000
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
Unsafe and Unsound Practices
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790
The Goldman Sachs Group, Inc.
October 22, 2020
DOJ (CRIM)
Deferred Prosecution Agreement
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
18 U.S.C. § 371 (General Conspiracy)
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791
Goldman Sachs (Malaysia) SDN. BHD.
October 22, 2020
DOJ (CRIM)
Plea Agreement
$1,263,088,000
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
18 U.S.C. § 371 (General Conspiracy)
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788
The Goldman Sachs Group, Inc.
October 21, 2020
NYDFS
Consent Order (C&D & CMP)
$150,000,000
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
3 NYCRR § 300.4 (Other Reports)
New York State Banking Law § 44 (Unsafe and Unsound Practices)
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784
Manufacturers & Traders Trust Company
October 14, 2020
FRB
Consent Order (CMP)
$546,000
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
12 C.F.R. § 208.25 (Loans in Special Flood Hazard Areas)
National Flood Insurance Act of 1968 and the Flood Disaster Protection Act of 1973, 42 U.S.C. § 4012a(f)(5)
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785
USAA Federal Savings Bank
October 14, 2020
OCC
Consent Order (CMP)
$85,000,000
Cybersecurity
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
Military Lending Act
Servicemembers Civil Relief Act
Unsafe and Unsound Practices
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787
First Abu Dhabi Bank USA, N.V.
October 9, 2020
OCC
Consent Order (CMP)
$5,000,000
BSA/AML
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
12 C.F.R. § 21.11 (SARs)
12 C.F.R. § 21.21 (BSA Program)
31 C.F.R. § 1010.610 (Due Diligence for Foreign Correspondent Accounts)
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783
Morgan Stanley Bank, N.A., and Morgan Stanley Private Bank, N.A.
October 8, 2020
OCC
Consent Order (CMP)
$60,000,000
Cybersecurity
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
12 C.F.R. Part 30, Appendix B (Information Security)
Unsafe and Unsound Practices
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781
Citibank, N.A.
October 7, 2020
OCC
Consent Order (CMP)
$400,000,000
Other
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
12 C.F.R. Part 30, Appendix D (Risk Governance Framework and Oversight)
Unsafe and Unsound Practices
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782
Citibank, N.A.
October 7, 2020
OCC
Consent Order (C&D)
Other
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
12 C.F.R. Part 30, Appendix D (Risk Governance Framework and Oversight)
Unsafe and Unsound Practices
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780
TD Bank, N.A.
August 19, 2020
CFPB
Consent Order (CMP)
$25,000,000
Consumer Compliance
No Yes No
LOOKBACK: No
REDRESS: Yes
RELEASE: No
Violations Cited:
12 C.F.R. § 1005.17 (Requirements for Overdraft Services)
12 U.S.C. §§ 5531, 5536 (Unfair, Deceptive or Abusive Acts and Practices/UDAAP)
Electronic Fund Transfer Act, 15 U.S.C. §§ 1693 et seq.
Fair Credit Reporting Act, 15 U.S.C. §§ 1681 et seq.
Regulation V, 12 C.F.R. §§ 1022.42 a-c (Accuracy and Integrity Furnished Information)
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777
Capital One, N.A., and Capital One Bank (USA), N.A.
August 5, 2020
OCC
Consent Order (C&D & CMP)
$80,000,000
Cybersecurity
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
12 C.F.R. Part 30, Appendix B (Information Security)
Unsafe and Unsound Practices
DOWNLOAD
776
Capital One Financial Corporation
August 4, 2020
FRB
Consent Order (C&D)
Cybersecurity
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
12 C.F.R. § 252.33(a)(2) (Adequate Risk-Management Framework)
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775
Bank of America, N.A.
July 23, 2020
DOJ (CIV)
Settlement Agreement
Fair Lending
Yes Yes Yes
LOOKBACK: Yes
REDRESS: Yes
RELEASE: Yes
Violations Cited:
Fair Housing Act, 42 U.S.C. §§ 3601 et seq.
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771
Deutsche Bank AG, Deutsche Bank AG New York Branch, and Deutsche Bank Trust Company of the Americas
July 6, 2020
NYDFS
Consent Order (CMP)
$150,000,000
BSA/AML
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
3 NYCRR § 116.2 (AML Program)
New York State Banking Law § 44 (Unsafe and Unsound Practices)
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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.