Recent Developments in the Financial Services Space

1. Debevoise Panel on Bank Regulation and Enforcement (October 6, 2015)

Notes from one of my colleagues that attended the panel:

“At today’s Debevoise Panel on Bank Regulation and Enforcement, a number of speakers, including Shari Leventhal, Deputy General Counsel at the NY Fed responsible for the Enforcement, Litigation and Investigations division of the Bank’s Legal Group, mentioned the renewed regulatory and enforcement focus on holding bank employees and directors responsible for bank compliance failures. They cited a September 9, 2015 memorandum issued by Deputy Attorney General Sally Yates (attached) which states that companies will no longer be given any credit for cooperation if they do not provide requested information on individuals responsible for bank misconduct. Speakers also mentioned a renewed focus on including individuals in enforcement actions and requiring them to be fined, removed from office or banned from serving in the financial services industry. The enforcement priority areas mentioned most frequently were Anti-Bribery and Corruption, AML and Sanctions, and Consumer/Default Management, with Cyber security enforcement actions in the wings after a short grace period.”

2. Poor cybersecurity controls may result in bank downgrades

Standard & Poor’s released a report in which it said that the agency may downgrade a bank’s rating if a lender has weak cybersecurity controls. 


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