On February 15, 2018, federal authorities - including the U.S. Department of Justice - filed charges against U.S. Bank, the fifth-largest commercial bank by assets in the United States, for allegedly neglecting anti-money laundering rules, helping a payday lender operate an illegal business and lying to a regulator.

In a settlement deal with the DOJ and other regulators, U.S Bank agreed to pay fines and penalties totaling $613 million. Separately, Manhattan federal prosecutors agreed to defer prosecution against the bank, so long as it could demonstrate that it had improved its monitoring of customer transactions.

Jeffrey Alberts, Chair of Pryor Cashman's White Collar Defense + Investigations practice, recently spoke with New York Times reporter Emily Flitter about the case: "There's no level of monitoring you can impose that will catch every single suspicious transaction," Alberts said, adding that scrutinizing potential criminal activity is a challenge for banks.

Alberts told Flitter that banks often struggle to determine how precisely they needed to monitor customer transactions to satisfy regulators.

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