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: June 26, 2020

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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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.
766
Bank Hapoalim B.M.
April 30, 2020
FRB
Consent Order (CMP & C&D)
$37,350,000
Tax
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
Unsafe and Unsound Practices
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769
Bank Hapoalim B.M. and Bank Hapoalim B.M., New York Branches
April 30, 2020
NYDFS
Consent Order
$220,000,000
Tax
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
3 NYCRR § 300.1 (Reporting of Crimes)
New York State Banking Law § 200-c (Maintenance of Books, Accounts and Records)
New York State Banking Law § 44 (Failure to Make Reports)
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770
Bank Hapoalim B.M. and Hapoalim (Switzerland) Ltd
April 30, 2020
DOJ (CRIM)
Non-Prosecution Agreement
$30,063,317
Tax
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
18 U.S.C. § 1956(h) (Money Laundering)
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767
Hapoalim (Switzerland) Ltd.
April 22, 2020
DOJ (CRIM)
Plea Agreement
$402,534,921
Tax
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
18 U.S.C. § 371 (Conspiracy to Defaud the United States)
26 U.S.C. § 7201 (Attempt to Evade or Defeat Tax)
26 U.S.C. § 7206(1) (Declaration under penalties of perjury)
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768
Bank Hapoalim B.M.
April 22, 2020
DOJ (CRIM)
Deferred Prosecution Agreement
$214,385,612
Tax
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
18 U.S.C. § 371 (Conspiracy to Defaud the United States)
26 U.S.C. § 7201 (Attempt to Evade or Defeat Tax)
26 U.S.C. § 7206(1) (Declaration under penalties of perjury)
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764
Industrial Bank of Korea and Industrial Bank of Korea, New York Branch
April 20, 2020
NYDFS
Consent Order (CMP)
$35,000,000
BSA/AML
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
3 NYCRR § 116.2 (AML Program)
New York State Banking Law § 200-c (Maintenance of Books, Accounts and Records)
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765
Industrial Bank of Korea
April 20, 2020
DOJ (CRIM)
Deferred Prosecution Agreement
$51,000,000
BSA/AML
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
31 C.F.R. § 1020.210 (BSA Program)
31 U.S.C. § 5318(h) (BSA Program)
31 U.S.C. § 5322(a) (BSA/AML fines)
31 U.S.C. § 5322(c) (number of BSA/AML violations)
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762
Wells Fargo & Company and Wells Fargo Bank N.A.
February 20, 2020
DOJ (CIV)
Settlement Agreement
$3,000,000,000
FIRREA
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
18 U.S.C. § 1005 (False bank entries, reports and transactions)
Financial Institutions Reform, Recovery, and Enforcement Act ("FIRREA"), 12 U.S.C. § 1833a (Civil Penalties)
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763
Wells Fargo & Company and Wells Fargo Bank N.A.
February 20, 2020
DOJ (CRIM)
Deferred Prosecution Agreement
$3,000,000,000
FIRREA
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
18 U.S.C. § 1005 (False bank entries, reports and transactions)
18 U.S.C. § 1028A (aggravated identity theft)
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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)
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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)
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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)
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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
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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)
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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.