carterj@ballardspahr.com | 215.864.8112 | view full bio

Juliana has trial experience with a range of criminal and civil disputes, and assists corporate and individual clients in white collar criminal defense matters. Her white collar practice includes providing advice regarding AML and BSA litigation and compliance, including matters involving suspicious activity reporting, alleged BSA violations by financial institutions, and the crafting of AML and anti-bribery compliance plans. During her judicial clerkship, Juliana handled several white-collar criminal cases, including a high-profile public corruption trial. Prior to joining the firm, she interned in the office of the Philadelphia District Attorney.

Last week, the Office of the Comptroller of the Currency (“OCC”) published the Spring 2018 Semiannual Risk Perspective (the “Report”), which uses up-to-date data to identify risks to U.S. banks and measure their compliance with applicable laws and regulations.  The Report concluded that some of the OCC’s primary concerns are with the elevation in operational risk “as banks adapt business models, transform technology and operating processes, and respond to evolving cyber threats.”  The Report also focused on elevated compliance risk associated with bank efforts to “manage money-laundering risks in a complex environment.”

Many of the OCC’s observations and recommendations remained the same from its Fall 2017 report, leaving readers to wonder what will spur less conversation and potentially more action among OCC-supervised banks or concrete guidance by the OCC.  Regardless, a common thread running throughout both reports is the potential risk presented to financial institutions by emerging technologies, which carry the simultaneous blessing and curse of greater business opportunities, but also greater operational and compliance risks.
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