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Key Issues and Impacts from Notable Enforcement Actions by U.S. Regulators in 2024

Abstract

This article explores three notable U.S. enforcement actions of 2024 and the key issues and impacts those enforcement actions impart, as we look to 2025 and beyond. In October 2024, TD Bank received a total penalty of over $3 billion, consisting of a $1.3 billion penalty for violations of Bank Secrecy Act (“BSA”) violations from the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”), a $1.8 billion penalty from the U.S. Justice Department (“USDOJ”), $450 million in penalties from the Office of the Comptroller of the Currency (“OCC”), and $123.5 million in penalties from the Federal Reserve Board (“FRB”). There are lessons learned from these different enforcements – shedding light into what mattered most at each agency and what financial institutions can do to prevent being in the same position as TD.

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Author

Portrait image of Elizabeth Fiorelli
Elizabeth Fiorelli
Assistant Adviser of Global Legal and Compliance , Sumitomo Mitsui Trust Bank, Limited, New York Branch, USA

Elizabeth Fiorelli is Head of Legal and Compliance Advisory, Sumitomo Mitsui Trust Bank, Limited, New York Branch. She is licensed as an attorney in the United States (in New York and in New Jersey). She has worked in the compliance industry for a number of financial institutions.

Company

Sumitomo Mitsui Trust Bank, Limited, New York Branch logo

Sumitomo Mitsui Trust Bank, Limited, New York Branch

SMTB is the largest trust bank in Asia and a major international bank with offices throughout Asia, Europe and the U.S. Its parent holding company, Sumitomo Mitsui Trust Holdings, Inc. is a financial conglomerate with a variety of financial institution subsidiaries, including in the banking, asset management, real estate brokerage and leasing sectors.

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