The Rise in Foreign Bank Enforcement Actions in New York
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- The New York Department of Financial Services (DFS) has been taking a more proactive enforcement approach with respect to the New York-licensed branches and New York-chartered bank subsidiaries of foreign banks.
- This change has been caused by DFS’s enhanced enforcement authority and the enforcement backgrounds of many of DFS’s senior personnel.
- Foreign banks with New York-licensed branches and New York-chartered banks may wish to consider DFS’s posture and fashion their dealings with DFS accordingly.