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In February 2009, the directors of Sykesville Federal Savings Association were collectively fined ,500 in non-reimbursable civil money penalties for multiple violations of a consent order to cease and desist.

In January 2013, the OCC levied civil money penalties against five D&O of Security Bank for up to ,000 per person in connection with violations including failure to ensure an effective BSA compliance and SAR reporting system.

He reiterated this goal in a focused speech before ACAMS in March 2014, suggesting that a stricter enforcement paradigm targeting individual accountability might emerge in the near future.

In each of these statements, bank D&O were mentioned as a class facing increased scrutiny from an individual liability perspective.

No, your HC2 automatically starts on the date your HC1 application was received by the NHS Business Services Authority (NHSBSA) and cannot be backdated under any circumstances.

If you have been sent a Penalty Charge Notice (PCN) relating to a prior NHS prescription, you will be liable for all charges unless you held any other valid exemption.

The shift toward individual accountability for BSA/AML violations has sparked some concerns that qualified personnel might avoid compliance or D&O positions at banks due to the risk of personal liability, especially due to the prohibition on institution-provided D&O civil money penalty insurance coverage.

The increasing trend in the penalties assessed as a share of total equity capital—conditional upon an enforcement action—has been striking.

As part of this aggressive enforcement paradigm, Fin CEN added a stand-alone Enforcement Division in June 2013 in a major internal reorganization, and Fin CEN also started placing emphasis on corporate and individual responsibility with respect to BSA/AML compliance.

In September 2013, the Justice Department charged the CEO of Public Savings Bank with criminal failure to file a SAR and maintain adequate AML controls in connection with an ,400 wire transfer of suspected drug money.

Though bank directors and officers are often covered by D&O liability insurance, for the past several years the Federal Deposit Insurance Corporation (FDIC) has taken an increasingly strong position that a financial institution’s insurance policies may not indemnify D&O for civil money penalties.

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