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: October 19, 2022

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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853
Nodus International Bank, Inc.
October 18, 2022
OFAC
Finding of violation (FOV)
BSA/AML & Sanctions
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
31 C.F.R. § 591 (Venezuela Sanctions Regulations)
31 CFR § 501 (Reporting, Penalties and Procedures Regulations)
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855
ICICI Bank Limited
October 3, 2022
OCC
Consent Order (C&D)
BSA/AML & Sanctions
Yes No No
LOOKBACK: Yes
REDRESS: No
RELEASE: No
Violations Cited:
12 C.F.R. § 21.11 (SARs)
12 C.F.R. § 21.21 (BSA Program)
12 U.S.C. § 1818(s) (BSA Program)
31 C.F.R. § 1010.230 (Beneficial Ownership Requirements for Legal Entity Customers)
31 C.F.R. § 1010.410 (Financial Institution Records)
31 C.F.R. § 1020.210 (BSA Program)
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851
Regions Bank
September 28, 2022
CFPB
Civil Money Penalty
$191,000,000
Unsafe and Unsound Practices
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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852
Lakeland Bank
September 28, 2022
DOJ
Consent Order
$13,150,000
Fair Lending
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
12 C.F.R. § 1002.1 et seq. (Equal Credit Opportunity Act - Regulation B)
15 U.S.C. §§ 1691-1691(f)
42 U.S.C. § 3601 et seq. (Fair Housing Act)
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850
Sterling Bank and Trust, FSB
September 27, 2022
OCC
Civil Money Penalty
$6,000,000
Unsafe and Unsound Practices, BSA/AML & Sanctions
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
12 C.F.R. § 1026 (Regulation Z of the Truth in Lending Act)
12 C.F.R. § 21.21(d) (Contents of compliance program)
18 U.S.C. § 1001 (Statements or entries generally)
California Penal Code § 532(f) (Mortgage Fraud)
New York State Penal Law § 187 (Residential Mortgage Fraud)
Unsafe and Unsound Practices
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849
Unity National Bank of Houston
August 29, 2022
OCC
Formal Agreement
Unsafe and Unsound Practices
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
Unsafe and Unsound Practices
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854
Blue Ridge Bank, National Association
August 29, 2022
OCC
Formal Agreement
BSA/AML & Sanctions
Yes No No
LOOKBACK: Yes
REDRESS: No
RELEASE: No
Violations Cited:
Unsafe and Unsound Practices
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848
EagleBank Corp.
August 15, 2022
FRB
Civil Money Penalty
$9,524,000
Unsafe and Unsound Practices
No No Yes
LOOKBACK: No
REDRESS: No
RELEASE: Yes
Violations Cited:
Regulation O, 12 C.F.R. §§ 215 et seq.
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847
U.S. Bank, N.A.
July 28, 2022
CFPB
Civil Money Penalty
$37,500,000
Consumer Compliance
No Yes Yes
LOOKBACK: No
REDRESS: Yes
RELEASE: Yes
Violations Cited:
Consumer Financial Protection Act of 2010, 12 U.S.C. § 5536
Fair Credit Reporting Act, 15 U.S.C. §§ 1681 et seq.
Truth in Lending Act, 15 U.S.C. §§ 1601 et seq.
Truth in Savings Act, 12 U.S.C. §§ 4301 et seq.
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846
American Express National Bank
July 15, 2022
OFAC
Settlement Agreement
$430,500
BSA/AML & Sanctions
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
31 C.F.R. § 598 (Foreign Narcotics Kingpin Sanctions Regulations)
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844
Bank of America, N.A.
July 14, 2022
OCC
Consent Order (C&D & CMP)
$125,000,000
Unsafe and Unsound Practices
Yes Yes Yes
LOOKBACK: Yes
REDRESS: Yes
RELEASE: Yes
Violations Cited:
15 U.S.C. § 45(a)(1) (Unfair or Deceptive Acts and Practices/UDAP)
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845
Bank of America, N.A.
July 14, 2022
CFPB
Civil Money Penalty
$100,000,000
Unsafe and Unsound Practices
Yes Yes Yes
LOOKBACK: Yes
REDRESS: Yes
RELEASE: Yes
Violations Cited:
12 C.F.R. § 1005.11 (Procedures for resolving errors)
12 U.S.C. §§ 5531, 5536 (Unfair, Deceptive or Abusive Acts and Practices/UDAAP)
15 U.S.C. § 1693g (Consumer liability)
15 U.S.C. § 1693f (Error resolution)
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843
Banco Popular de Puerto Rico
May 27, 2022
OFAC
Settlement Agreement
$255,937
BSA/AML & Sanctions
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
31 C.F.R. § 591 (Venezuela Sanctions Regulations)
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842
Bank of America, N.A.
May 4, 2022
CFPB
Civil Money Penalty
$10,000,000
Unsafe and Unsound Practices
No Yes No
LOOKBACK: No
REDRESS: Yes
RELEASE: No
Violations Cited:
12 U.S.C. §§ 5531, 5536 (Unfair, Deceptive or Abusive Acts and Practices/UDAAP)
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839
USAA Federal Savings Bank
March 17, 2022
OCC
Consent Order (C&D)
BSA/AML & Sanctions
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
12 C.F.R. § 163.180 (SARs)
12 C.F.R. § 21.21 (BSA Program)
12 U.S.C. § 1818(s) (BSA Program)
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840
USAA Federal Savings Bank
March 17, 2022
OCC
Civil Money Penalty
$60,000,000
BSA/AML & Sanctions
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
12 C.F.R. § 163.180 (SARs)
12 C.F.R. § 21.21 (BSA Program)
12 U.S.C. § 1829(b) (BSA-Recordkeeping)
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841
USAA Federal Savings Bank
March 17, 2022
FinCEN
Civil Money Penalty
$80,000,000
BSA/AML & Sanctions
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
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)
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838
National Bank of Pakistan
February 24, 2022
FRB/NYDFS
Consent Order (C&D & CMP)
$20,400,000
BSA/AML & Sanctions
No No No
LOOKBACK: No
REDRESS: No
RELEASE: No
Violations Cited:
12 C.F.R. § 211.24(f) (BSA Program)
12 C.F.R. § 211.24(j) (BSA Program)
26 C.F.R. §1.162-21 (Denial of deduction for certain fines, penalties, and other amounts)
26 U.S.C. § 162 (Trade or business expenses)
31 C.F.R. Chapter X (FinCEN Regulations)
31 U.S.C. §§ 5311-5330
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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.