The New York Department of Financial Services (DFS)
August 6 order against the New York subsidiary of Standard
Chartered and subsequent $340 million settlement is thought to
have changed the rules of regulatory compliance for foreign
The order has left foreign banks uncertain of what to think
now that state-level regulators have a roadmap for pursuing
claims resulting from attempts to circumvent federal laws.
This tells me that the state regulators apparently are
not working in concert with federal regulators, Venable
partner Edward Wilson said. It means the foreign banks
have to be more careful.
Wilson added that foreign banks liability can now come
from a state regulator to which they may not have previously
paid much attention.
The DFS order was based on alleged violations of New York
state banking laws requiring accurate reporting of transaction
originators and beneficiaries, which were either...