Recent Enforcement Actions against Foreign Banks in New York Suggest More to Come

By Daniel Bethencourt

The U.S. Federal Reserve on Thursday ordered the New York branch of South Korea's NongHyup Bank to upgrade its anti-money laundering, customer due-diligence and suspicious activity monitoring programs. The 8-page enforcement action does not carry a monetary penalty and provides only scant details of NongHyup's compliance failures, but broadly calls on its directors to acquire and demonstrate that they "possess appropriate subject matter expertise." The bank must also ensure that AML staff have sufficient resources and share relevant and timely information with the board. Perhaps more importantly, the action marks at least the fifth time in the past six months...