On Dec. 18, 2014, the Financial Crimes Enforcement Network issued a first-of-its-kind $1-million assessment against the former chief compliance officer and senior vice president of government affairs at MoneyGram International Inc. Separately, on Dec. 22, 2014, Bank Leumi USA and Bank Leumi Le-Israel, B.M. entered into a consent order with the New York State Department of Financial Services, under which the Bank admitted engaging in an illegal cross-border scheme to assist U.S. clients in evading federal and state taxes and agreed to pay DFS $130 million and hire an independent monitor. Bank Leumi further agreed to take steps to terminate and/or ban specific employees, including its former CCO, from engaging in compliance functions.

Click here to read this article, the second in a two-part series, in which SRZ attorneys Betty Santangelo, Gary Stein, Jennifer M. Opheim, Seetha Ramachandran and Melissa G.R. Goldstein continue their discussion on recent enforcement actions against compliance officers.