As we begin to prepare for a full schedule of events in 2024, starting with an event on Voluntary Self-Disclosure Policy for Export Controls Violations on January 16, 2024, the NYU School of Law Program on Corporate Compliance and Enforcement (PCCE) is taking a moment to reflect on our busy Fall 2023 program. In this post: our third annual PCCE Directors’ Academy on September 21-22, 2023.
Keynote speaker Heather Lavallee, CEO, Voya Financial, Inc. (©Hollenshead: Courtesy of NYU Photo Bureau)
by Stephen Cutler, Lee Meyerson, Keith Noreika, Adam Cohen, and Spencer Sloan
On October 7, the Office of the Comptroller of the Currency assessed a $400 million civil money penalty against Citibank, N.A. related to deficiencies in enterprise-wide risk management, compliance risk management, data governance and internal controls, and issued a cease and desist order requiring Citibank to take comprehensive corrective actions. Concurrently, the Federal Reserve issued a separate cease and desist order requiring Citibank’s parent, Citigroup Inc., to enhance its firm-wide risk management and internal controls as a result of Citigroup’s failure to adequately remediate “longstanding enterprise-wide risk management and control deficiencies” previously identified by the Federal Reserve in consent orders from 2013 and 2015.