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: August 5, 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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RESULTS (17 of 400+ | Log In to See More)
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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.
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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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
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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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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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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.