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 and select other federal and state agencies. 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: March 22, 2017

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448
Merchants Bank of California, N.A.
February 16, 2017
FinCEN
Consent Order (CMP)
$7,000,000
BSA/AML
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
12 C.F.R. § 21.21 (BSA Program)
31 C.F.R. § 1010.610 (Due Diligence for Foreign Correspondent Accounts)
31 C.F.R. § 1020.210 (BSA Program)
31 C.F.R. § 1020.320 (SARs)
31 U.S.C. § 5318(g) (SARs)
31 U.S.C. § 5318(h) (BSA Program)
31 U.S.C. § 5318(i) (Due Diligence for Foreign Correspondent Accounts)
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447
Merchants Bank of California, N.A.
February 14, 2017
OCC
Consent Order (CMP)
$1,000,000
BSA/AML
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
12 C.F.R. § 21.21 (BSA Program)
Violation of Prior Order
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451
Deutsche Bank AG; Deutsche Bank AG (New York Branch)
January 30, 2017
NYDFS
Consent Order (CMP)
$425,000,000
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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444
ServiceLink Holdings LLC
January 23, 2017
FRB
Consent Order (CMP)
$65,000,000
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
Unsafe and Unsound Practices
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445
ServiceLink Holdings LLC
January 23, 2017
OCC
Consent Order (CMP)
$65,000,000
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
Unsafe and Unsound Practices
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446
ServiceLink Holdings LLC
January 23, 2017
FDIC
Consent Order (CMP)
$65,000,000
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
Unsafe and Unsound Practices
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442
Western Union Financial Services, Inc.
January 19, 2017
FinCEN
Consent Order (CMP)
$184,000,000
BSA/AML
No Yes Yes
LOOKBACK: No
REDRESS: Yes
RELEASE: Yes
Violations Cited:
18 U.S.C. § 1342 (Fictitious Name or Address)
18 U.S.C. § 1343 (Wire Fraud)
31 C.F.R. § 1020.320 (SARs)
31 C.F.R. § 1022.210 (AML Program)
31 U.S.C. § 5318(h) (BSA Program)
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443
Western Union Company
January 19, 2017
DOJ (Crim)
Deferred Prosecution Agreement
$586,000,000
BSA/AML
No Yes Yes
LOOKBACK: No
REDRESS: Yes
RELEASE: Yes
Violations Cited:
18 U.S.C. § 2 (Aiding and Abetting)
31 U.S.C. § 5318(h) (BSA Program)
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437
HSBC USA Bank, N.A.
January 6, 2017
OCC
Consent Order (CMP)
$32,500,000
Mortgages
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
Unsafe and Unsound Practices
Violation of Prior Order
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436
TransUnion Interactive, Inc.; TransUnion, LLC; TransUnion
January 3, 2017
CFPB
Consent Order (CMP & C&D)
$3,000,000
Consumer Compliance
No Yes Yes
LOOKBACK: No
REDRESS: Yes
RELEASE: Yes
Violations Cited:
12 U.S.C. §§ 5531, 5536 (Unfair, Deceptive or Abusive Acts and Practices/UDAAP)
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435
Banco Bilbao Vizcaya Argentaria, S.A.; BBVA Securities Inc., New York
December 19, 2016
FRB
Consent Order (CMP)
$27,000,000
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
12 C.F.R. § 211.605 (Permissible Underwriting Activities of Foreign Banks)
12 U.S.C. § 1843 (Interests in Nonbanking Organizations)
12 U.S.C. § 1844(c) (Reports and Examinations of Bank Holding Companies)
12 U.S.C. §§ 371c, 371c-1 (Transactions with Affiliates)
Unsafe and Unsound Practices
Violation of Prior Order
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433
JPMorgan Chase & Co.
November 17, 2016
FRB
Consent Order (CMP)
$61,932,500
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
Unsafe and Unsound Practices
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434
JPMorgan Securities (Asia Pacific) Limited; JPMorgan Chase & Co.
November 17, 2016
DOJ (Crim)
Non Prosecution Agreement
$72,000,000
Other
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
Unspecified
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440
Wells Fargo Bank, N.A.
September 29, 2016
OCC
Consent Order (CMP)
$20,000,000
Other
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
Servicemembers Civil Relief Act, 50 U.S.C. App. §§ 501 et seq.
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441
Wells Fargo Bank, N.A.
September 29, 2016
OCC
Consent Order (C&D)
Other
No Yes Yes
LOOKBACK: No
REDRESS: Yes
RELEASE: Yes
Violations Cited:
Servicemembers Civil Relief Act, 50 U.S.C. App. §§ 501 et seq.
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For this purpose, "significant" is defined as (1) an action against a Global Systemically Important Bank or (2) 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.

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.