Simpson Thacher Attorneys Author Article on Noteworthy Takeaways from Recent Bank Regulatory Enforcement Actions
10.26.20
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Partners Stephen Cutler, Lee Meyerson and Keith Noreika, Counsel Adam Cohen and Associate Spencer Sloan authored an article titled, “Key Takeaways From Bank Regulatory Enforcement Actions Against Citi,” which was published by NYU School of Law's Compliance & Enforcement Blog. The article analyzed recent regulatory enforcement actions from the OCC and the Federal Reserve and highlighted noteworthy takeaways from the two orders. These included the significant penalty despite the absence of customer harm or bank losses; the possibility to expand the OCC’s order to cover future deficiencies; the requirement that general counsel oversee the compliance function; and the resulting oversight and restrictions on future significant acquisitions.
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