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Financial Services Investigations

As a stricter regulatory and prosecutorial landscape continues to emerge, the financial sector can expect even greater scrutiny and monitoring. We help clients navigate these evolving challenges in the highly-regulated financial services industry with a multidisciplinary approach that mitigates the risks of enforcement action or litigation. Major financial institutions, board committees, bank holding companies, bank officers and directors, and trading firms routinely seek our counsel to lead their response to internal and government investigations and enforcement proceedings that involve virtually every investigative agency.

With a combination of sophisticated business acumen and extensive industry knowledge, we anticipate potential issues before they escalate, identify opportunities, and effectively respond to the full spectrum of financial services investigations. Our strength lies in navigating the process with clients at each turn to help ensure the most favorable outcomes possible are obtained. While we are known for our involvement in numerous high-profile enforcement and investigation matters, we measure success by the number we have handled that will never become public.

  • Recognized Regulatory Leaders: We are banking lawyers who know how to conduct investigations. With one of the most well-established and highly regarded Financial Services practices in the U.S., our robust team assists on a full range of matters, including compliance investigations, administrative and congressional inquiries, regulatory advice, critical compliance disclosures, and enforcement matters. We routinely appear before state and federal law enforcement and regulatory agencies in matters involving fraud, corruption, competition/cartel issues, anti-money laundering, and securities trading, among other issues.

  • Elite Government Experience: Our many former government officials bring insider experience and depth of credibility that few firms can match. We have lawyers who have served in senior leadership and staff positions at federal and state regulators, including: the Federal Reserve; OCC; FDIC; OFAC; CFPB; DOJ (including offices of U.S. Attorneys, state attorneys general, and district attorneys); SEC; and the UK’s Serious Fraud Office.

  • Strategic Internal Investigations: We offer decades of experience conducting internal investigations in response to both internally identified concerns and regulatory inquiries. Our scope of experience spans insider misconduct, compliance deficiencies, whistleblower allegations, and securities trading to governance assessments and export/import controls. In addition, clients regularly engage us for guidance on matters involving anti-money laundering / Bank Secrecy Act, allegations of unsafe or unethical business practices, fair lending, and consumer protection issues.

Experience Highlights

  • Financial institution in parallel enforcement proceedings, including investigations by the Office of the Comptroller, Department of Justice (DOJ), and Securities and Exchange Commission relating to the bank’s most significant residential lending program and related anti-money laundering, accounting, financial reporting, and disclosure matters.

  • Nonbank financial institution in responding to civil investigative demands from the Consumer Financial Protection Bureau and the Federal Trade Commission, and document request subpoenas from the California State Department of Justice involving lending and sales practices.

  • Financial institution in a fair lending investigation by the Housing and Civil Enforcement Section, Civil Rights Division, DOJ, and the U.S. Attorney’s Office for the Middle District of North Carolina.

  • Financial institution in an internal investigation relating to potential noncompliance with Bank Secrecy Act/Anti-Money Laundering reporting obligations and related, ongoing remediation.

  • Financial institution in an internal investigation and related anti-money laundering and enforcement issues.

  • Fintech company in a New York Attorney General investigation regarding business and advertising practices.

  • Outside directors of a failed financial institution with respect to administrative and congressional inquiries.

  • Financial institution in investigations by DOJ and Small Business Administration (SBA) Office of Inspector General relating to SBA’s Paycheck Protection Program.

  • Foreign banking organization in an investigation by the U.S. Attorney’s Office for the Southern District of New York, the Office of Foreign Assets Control, the Federal Reserve Board, the New York Attorney General’s Office, and the New York Department of Financial Services for allegedly violating Iran and other sanctions.

  • Financial institution in an internal investigation relating to alleged money laundering through venture capital firm customers.