Last month, the U.S. Department of Justice initiated and immediately settled the first lawsuit under "Operation Choke Point," a coordinated multiagency enforcement initiative targeting banks serving online payday lenders and other companies of regulatory concern. The DOJ lawsuit was brought against Four Oaks Bank and Trust, a small North Carolina bank that processed ACH transactions through a third-party processor for online payday lenders and other companies of concern to the DOJ. The lawsuit sheds new light on government expectations for banks and other companies, including expectations that banks should deny services to perceived fraudsters and problem companies.

In this webinar, we will analyze the Four Oaks complaint and settlement, and discuss what the lawsuit means for banks and their ACH customers, including third-party processors and payday lenders.


  • Wire fraud theories in Four Oaks
  • Dealing with the DOJ
  • How enforcement actions can create non-legislative "rules" for behavior
  • DOJ criticisms in Four Oaks of originator practices
  • Terms of the Four Oaks settlement
  • Implications for banks
  • Implications for bank customers


12:00 PM - 1:00 PM ET | Webinar


Alan S. Kaplinsky, Practice Leader
Consumer Financial Services Group


Jeremy T. Rosenblum, Practice Leader
Consumer Financial Services Group

Marjorie J. Peerce
Consumer Financial Services Group
White Collar Defense/Internal Investigations Group

Mark J. Furletti
Consumer Financial Services Group

This program is open to Ballard Spahr clients and members of the financial services industry. There is no cost to attend. This program is not eligible for continuing education credits.

Please register at least two days before the webinar. Login details will be sent to all approved registrants. For more information, contact Lisa Prickril at

Related Practices

Consumer Financial Services
White Collar Defense/Internal Investigations