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As BuzzFeed reported, “laws that were meant to stop financial crime have instead allowed it to flourish. In terms of dollar amounts, Deutsche led the pack at $1.3 trillion in suspicious transactions; J.P.Morgan followed with $514 million and Standard Chartered logged $166 million. The headlines blare a chorus: Banks are not doing their jobs.
The director may determine the merits of the appeal, or at the election of the financial institution, refer the appeal to an administrative law judge appointed by the FFIEC to conduct a hearing. In any hearing, neither the director nor the administrative law judge could defer to the opinions of the examiner or agency.
Those agencies include the aforementioned FinCEN, the Federal Reserve , the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA) and the Office of the Comptroller of the Currency (OCC).
As evidence of this, Rodney Hood, the former chairman of the National Credit Union Administration Board (NCUA) , was appointed to be the acting comptroller on Feb. But that did not lead to him being nominated for the comptroller position. If confirmed, he will return to the FDIC board, along with the Comptroller.
the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), or the National Credit Union Administration (NCUA)) are not included in the Working Group, especially given the allegations of an ‘Operation Choke Point 2.0.,’
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