Sumitomo Mitsui Trust Bank, Limited and Sumitomo Mitsui Trust Holdings, Inc.
Corporate Conglomerates:
Advantages, Disadvantages, Successes and Failures, Including Case Studies of General Electric and Berkshire Hathaway

This article discusses the rise and fall of corporate structures commonly referred to as “conglomerates.” They represent a collection of different companies, either in distinct industries or concentrated in one...Read more
Bruce Ortwine
General Counsel (retired), Americas; Adviser, Global Legal and Compliance (Retired), Sumitomo Mitsui Trust Bank, Limited and Sumitomo Mitsui Trust Holdings, Inc., USA
Proposed FDIC Guidelines with Impose New Responsibilities on Directors of FDIC-Insured Banks 
On October 11, 2023, the Federal Deposit Insurance Corporation (the “FDIC”) issued proposed mandatory Guidelines (the “Guidelines”) concerning the roles and responsibilities of directors of banks whose deposits are insured...Read more
Bruce Ortwine
General Counsel (retired), Americas; Adviser, Global Legal and Compliance (Retired), Sumitomo Mitsui Trust Bank, Limited and Sumitomo Mitsui Trust Holdings, Inc., USA
Certain Regulatory Reporting Requirements for a Foreign Banking Organization in the United States
My former employer of thirty-three years is a Japanese financial institution (the “Bank”) and is subject to comprehensive regulation in the United States at both the Federal and State levels....Read more
Bruce Ortwine
General Counsel (retired), Americas; Adviser, Global Legal and Compliance (Retired), Sumitomo Mitsui Trust Bank, Limited and Sumitomo Mitsui Trust Holdings, Inc., USA
U.S. Plays Catch-up to Close Long-Standing Gaps in Anti-Money Laundering Laws: Part Two: Focus on Real Estate Transactions

Part One of this Article focused on the U.S. Government’s anti-money laundering/contra terrorist financing (“AML”) efforts, certain deficiencies in the 2001 USA Patriot Act, which was enacted following the terrorist...Read more
Bruce Ortwine
General Counsel (retired), Americas; Adviser, Global Legal and Compliance (Retired), Sumitomo Mitsui Trust Bank, Limited and Sumitomo Mitsui Trust Holdings, Inc., USA
U.S. Plays Catch-up to Close Long-Standing Gaps in Anti-Money Laundering Laws: Part One
The U.S. Government finally seems to begin focusing on closing long-standing and significant gaps in existing anti-money and contra-terrorist financing laws (together, “AML”) that have been in existence for nearly...Read more
Bruce Ortwine
General Counsel (retired), Americas; Adviser, Global Legal and Compliance (Retired), Sumitomo Mitsui Trust Bank, Limited and Sumitomo Mitsui Trust Holdings, Inc., USA
One Company’s Response to the COVID-19 Pandemic
I first learned about a strange new virus emanating from Central China during a business lunch meeting in Tokyo in mid-January 2020. My Japanese colleague knew few details about the...Read more
Bruce Ortwine
General Counsel (retired), Americas; Adviser, Global Legal and Compliance (Retired), Sumitomo Mitsui Trust Bank, Limited and Sumitomo Mitsui Trust Holdings, Inc., USA
Critique of the U.S. Department of Justice Evaluation of Corporate Compliance Programs
On April 30, 2019, the U.S. Department of Justice, Criminal Division (the “DOJ”) published updated guidance (the “DOJ Guidance”) on the evaluation of a company’s corporate compliance program (a “CCP”)....Read more
Bruce Ortwine
General Counsel (retired), Americas; Adviser, Global Legal and Compliance (Retired), Sumitomo Mitsui Trust Bank, Limited and Sumitomo Mitsui Trust Holdings, Inc., USA
Compliance with New Anti-Money Laundering Requirements in
New York State

Anti-money laundering requirements, specifically those prohibiting the funding of countries and entities subject to U.S. sanctions laws, continue to be a top priority of bank regulatory agencies in the United...Read more
Bruce Ortwine
General Counsel (retired), Americas; Adviser, Global Legal and Compliance (Retired), Sumitomo Mitsui Trust Bank, Limited and Sumitomo Mitsui Trust Holdings, Inc., USA
Organizational Compliance Failures Quickly Become a Legal Problem

Legal and compliance are two essential functions in any contemporary organizational structure. The specific relationship between these two functions, including reporting lines and division of responsibilities, may well vary depending...Read more
Bruce Ortwine
General Counsel (retired), Americas; Adviser, Global Legal and Compliance (Retired), Sumitomo Mitsui Trust Bank, Limited and Sumitomo Mitsui Trust Holdings, Inc., USA
Public Enemy Number One: The Current Standing of Banks in the United States

Since the financial meltdown of 2008, highlighted by the Lehman Brothers collapse on September 15, the standing of banks in the United States has declined precipitously, with no current prospects...Read more
Bruce Ortwine
General Counsel (retired), Americas; Adviser, Global Legal and Compliance (Retired), Sumitomo Mitsui Trust Bank, Limited and Sumitomo Mitsui Trust Holdings, Inc., USA