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Financial Services Law Insights and Observations

New York Financial Regulator Obtains Settlement on AML Charges

Anti-Money Laundering Sanctions

State Issues

On August 14, the New York Superintendent of Financial Services announced the resolution of recent charges that a British bank and its U.S. subsidiary engaged in deceptive and fraudulent misconduct in order to move substantial funds on behalf of client Iranian financial institutions that were subject to U.S. sanctions. While the details of the settlement have not been released, the Superintendent stated that the bank must (i) pay a civil penalty of $340 million to the New York State Department of Financial Services (DFS), (ii) install a monitor for a term of at least two years who will report directly to DFS and who will evaluate the money-laundering risk controls in the New York branch and implementation of appropriate corrective measures, (iii) allow DFS examiners to be placed on site at the bank, and (iv) permanently install personnel within its New York branch to oversee and audit the bank’s offshore money-laundering due diligence and monitoring program.