Recent Developments in BSA/AML: Federal Reserve Enters Into Written Agreements with Discover Financial Services and State Street Corporation

Sullivan & Cromwell LLP - June 3, 2015
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Over the past week, the Board of Governors of the Federal Reserve (the “Federal Reserve”) announced two enforcement actions addressing Bank Secrecy Act (“BSA”)/anti-money laundering (“AML”) compliance program deficiencies.  Contemporaneous with those announcements, the Vice Chairman of the Federal Reserve noted in a speech the “massive fines being imposed on banks” but the absence of personal accountability.  Consistent with our observations earlier this year, U.S. regulators continue to focus their enforcement efforts on BSA/AML compliance and continue to stress the importance of personal accountability.