• Recent Developments in BSA/AML: Federal Reserve Enters Into Written Agreements with Discover Financial Services and State Street Corporation
  • June 8, 2015 | Authors: Nicolas Bourtin; H. Rodgin Cohen; Elizabeth T. Davy; Mitchell S. Eitel; Jared M. Fishman
  • Law Firm: Sullivan & Cromwell LLP - New York Office
  • 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.