The New York State Department of Financial Services (DFS) continues to aggressively pursue economic sanctions enforcement, as evidenced by the $420 million fine recently levied on Société Générale for sanctions violations and anti-money laundering deficiencies. As New York’s top financial regulator, DFS oversees state-chartered banks, foreign bank branches and representative offices, insurance companies, money transmitters, and many other financial institutions.

DFS has historically taken the lead in bringing enforcement actions against regulated entities, many of which include foreign banks, for payment processing practices that the Department determines to be “non-transparent.” In recent years, large banks such as Deutsche Bank AG, Standard Chartered Bank, BNP Paribas, S.A., Commerzbank AG, Intesa Sanpaolo S.p.A, Agricultural Bank of China, and Habib Bank Limited have paid significant monetary fines for such violations. DFS’s recent enforcement action and fine against Société Générale further demonstrates its commitment to aggressive enforcement. In short, DFS is not slowing down.