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Robert M. Axelrod

The Feb. 21, 2019 OCC Consent Order with MUFG branch banks had two purposes. The commonplace one was to resolve a looming cease and desist action around anti-money laundering issues with the traditional comprehensive regulatory menu of action plans, risk assessments, due diligence prescriptions, transaction monitoring and auditing improvements. The unusual other purpose was for it to be filed by the OCC (as amicus) in the pending (2017) action between MUFG and the New York State Department of Financial Services (DFS). In that action, MUFG sought to prevent DFS from continuing to supervise MUFG after MUFG switched its banking license to the OCC, and the DFS complained that OCC had made an abrupt, improvident and meretricious license transfer decision. The OCC defended itself, in an amicus brief, as having gone through its usual processes, while the DFS contended in its answer and counterclaims (Answer) that it was about to bring its own enforcement action and that MUFG switched regulators to get an easier hand. The context of the prior action was further elaborated upon in my Sept. 11, 2018 article in this journal.

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