OCC Assesses a $15 Million Civil Money Penalty for Governance and Oversight of Third-Party Affiliate

Today, the Office of the Comptroller of the Currency (OCC) announced a $15 million civil money penalty against American Express National Bank (American Express). The penalty is a result of American Express failing to govern and oversee a third-party affiliate and for violations of regulations relating to certain efforts to retain small business customers. This is the first CMP issued since the agencies released their interagency guidance on June, 9th. The OCC found that American […]

FinCEN Proposes Rule

On July 30, 2014, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) that, if finalized, will amend the Bank Secrecy Act regulations to enhance customer due diligence (CDD) requirements imposed on financial institutions (i.e. banks, brokers and dealers in securities, mutual funds, and future commission merchants and introducing brokers in commodities).  In an effort to increase financial transparency and protect the financial system from […]