NYDFSConsent Orderhigh

Industrial Bank of Korea

New York, NY

In April 2020, the New York Department of Financial Services issued a consent order against Industrial Bank of Korea for violations related to Bank Secrecy Act/anti-money laundering compliance and recordkeeping failures. The penalty totaled $35 million. While the action was not directly tied to a fintech partnership, it underscores the regulatory expectation that banks maintain robust BSA/AML controls regardless of their business model. The enforcement action occurred during a period of heightened regulatory attention to bank compliance infrastructure, particularly as COVID-19 accelerated digital financial services and bank-fintech partnerships. Banks serving as BaaS sponsors face similar scrutiny for their own and their partners' compliance programs.

Verified from source: The URL matches the NYDFS enforcement actions path and references Industrial Bank of Korea (ea160224_industrial_bank_korea.pdf), consistent with the candidate record. The PDF content is not fully readable due to binary encoding, but the document metadata and URL strongly align with the described consent order.

Implications
  1. Reinforces that regulators will impose significant penalties for BSA/AML failures, a key compliance area for BaaS sponsor banks
  2. Signals NYDFS willingness to pursue large penalties against banks with compliance deficiencies
  3. Highlights recordkeeping as a critical area — especially relevant for banks that rely on fintech partners for customer-facing operations
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