The consent agreement will resolve issues relating to instructions given to PricewaterhouseCoopers (“PwC”) and the disclosures made to the DFS in connection with BTMU’s 2007 and 2008 voluntary investigation of BTMU’s U.S. dollar clearing activity toward countries under U.S. economic sanctions. BTMU had hired PwC to conduct a historical transaction review report in connection with that investigation.
Under the terms of the agreement with DFS, BTMU will make a payment of $315m to DFS, take actions on persons involved in the matter at that time, and relocate its U.S. BSA/AML and OFAC sanctions compliance programs to New York, and extend, if regarded as necessary by DFS, the period during which a third party organization is responsible for assessing BTMU’s internal controls regarding compliance with applicable laws and regulations related to U.S. economic sanctions.
BTMU voluntarily submitted the report to DFS’s predecessor agency in 2008. BTMU had reached an agreement with DFS in June 2013 regarding inappropriate operational processing of U.S. dollar clearing transactions with OFAC-sanctioned countries during the period of 2002 to 2007.
BTMU is committed to conducting business with the highest levels of integrity and regulatory compliance, and to continually improving its policies and procedures.