In Battle Against OCC, Ex-Compliance Chief Faces Uncertain, Possibly Dim, Outcome

In April 2018, the Office of the Comptroller of Currency (OCC) filed notice of charges seeking a $50,000 monetary penalty against Laura Akahoshi, the former chief compliance officer of Rabobank N.A., after the bank pleaded guilty to attempting to conceal from the OCC alleged anti-money laundering deficiencies. After the OCC abandoned its administrative enforcement case against Ms. Akahoshi in April 2023, she fired back and sought both appellate review of that dismissal, and reimbursement for her legal fees.

“I don’t think [Ms. Akahoshi’s case] will undercut [the OCC’s] enforcement powers,” Peter D. Hardy told ACAMS MoneyLaundering.com. “I think what it will do is send a message to agencies that, if they’re going to dismiss the case, they should not do so in an order that lays out their belief to the contrary.”

Mr. Hardy co-leads and is the founder of Ballard Spahr's Anti-Money Laundering Team. He and Alexa L. Levy wrote "Former Bank Compliance Chief Seeks Appellate Review of OCC Administrative Enforcement Proceeding Dismissal" on this same issue on Money Laundering Watch, the firm's blog covering insights and news on the world of financial corruption.

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