Federal Reserve Issues Two BSA/AML Enforcement Actions; Federal Reserve Vice Chairman Emphasizes the Need for Personal Accountability

June 3, 2015

Over the past week, the Board of Governors of the Federal Reserve System announced two enforcement actions addressing Bank Secrecy Act (BSA)/anti-money laundering (AML) compliance program deficiencies against Discover Financial Services and State Street Corporation. Concurrent with the State Street announcement, Stanley Fischer, vice chairman of the Federal Reserve, noted in a speech the “massive fines being imposed on banks,” but the absence of personal accountability, and called for punishment of individuals for misconduct. Consistent with our observations earlier this year, U.S. regulators continue to focus their enforcement efforts on BSA/AML compliance and to be unsatisfied with the level of personal accountability.  BSA/AML compliance risk management should continue to be a focus of boards of directors and senior management of financial institutions.  See our memorandum to clients titled “Federal Reserve Board Enters into Written Agreements with Discover Financial Services and State Street Corporation” for more information.