Federal Bank Regulators Step Up Enforcement Actions

Over the past two or three years, the number of enforcement actions brought by each of the federal bank regulators has increased, and the focus of the agencies has changed. A number of additional agencies and government entities have also begun exercising their enforcement powers. This uptick in the number of actions follows a period of relative calm in the enforcement area. The industry continues to be in good financial health, and as a result the actions generally are not for the type of activities and actions that brought the industry the Financial Institutions Reform Recovery and Enforcement Act of 1989, the Crime Control Act of 1990, and the Federal Deposit Insurance Corp. Improvement Act of 1991. The actions of the recent past have been largely for violations of the Bank Secrecy Act, the USA Patriot Act, and the rules and regulations that implement the privacy and information security requirements.