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- SEC $151 M Fine for JP Morgan; Google on AI Risk Management for Banking; AML Scrutiny Continues
SEC $151 M Fine for JP Morgan; Google on AI Risk Management for Banking; AML Scrutiny Continues
Hello everyone! Welcome back to the Risk Queue. This week, JP Morgan takes a big hit on conduct risk, Google takes on AI Risk in Banking and the AML scrutiny continues at a major bank. Let’s jump in!
-Enjoy, Naeem, CEO & Founder - Risk On Q
PICKS:
Fines - JP Morgan conduct review
Regulators - AML risk review
AI - Google’s view on AI risk in Banking
Risk Headlines
SEC Fines JP Morgan $151 Million for Five Enforcement Actions - source Reuters.com
Key Points:
JPMorgan Chase faces a $151 million settlement with the SEC covering five distinct enforcement cases, primarily centered around disclosure inadequacies and conflicts of interest across wealth management. The most significant case involves $100 million related to "conduit" products, where disclosure issues about discretionary trading authority created customer risk exposure. While the bank's self-reporting on the ETF matter resulted in penalty avoidance, the breadth of issues across multiple business lines suggests a need for comprehensive review of disclosure practices and conflict management procedures, expect other Firms to receive similar reviews.
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Banks’ Strategy of Extending Commercial Loans Found to Escalate Financial Risk - source costar.com
Key Points:
The banking sector faces a critical juncture with the New York Fed warning of increasing financial fragility due to widespread "extend-and-pretend" practices in commercial real estate lending. With a $1.26 trillion maturity wall peaking in 2027, combined with a 20% decline in property values and nearly 2,000 banks exceeding regulatory CRE exposure thresholds, the industry faces potential widespread defaults and consolidation, particularly among regional and smaller banks.
A.I. Risk / Technology Risk
Google & AIR Set Out Framework for AI Risk in Banking Sector - source fintechmagazine.com
Key Points:
The convergence of generative AI and banking presents a transformative opportunity worth £270B annually, but requires fundamental redesign of risk management frameworks. Google Cloud and AIR's framework highlights critical gaps in current governance structures and regulatory guidance, while emphasizing the urgent need for industry-wide collaboration.
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Beyond the Hype - Adopting Generative AI in Banking with Deutsche Bank - source corporates.db.com
Key Points:
Generative AI presents a transformative opportunity for banks to enhance productivity and competitive advantage through improved compliance, client engagement, and risk management. A structured, three-stage implementation approach is recommended, starting with basic text analysis and progressing to more complex autonomous capabilities. Success depends on robust quality controls, risk management frameworks, and careful consideration of regulatory requirements, with particular attention to data quality and cybersecurity. Successful GenAI adoption in banking requires a methodical, risk-aware approach that balances innovation with robust controls.
Regulatory News - Fines, Losses, & Rules
Bank of America is the latest Bank to Face AML Scrutiny - source American Banker at yahoo.com
Key Points:
Bank of America faces heightened regulatory scrutiny over its AML compliance program, following a pattern seen with TD Bank and Wells Fargo's recent enforcement action. While the bank doesn't expect material financial impact, potential growth restrictions could affect expansion plans across consumer banking, payments, and trading. This regulatory focus, combined with the separate CFPB Zelle investigation, signals increasing regulatory attention on both traditional AML risks and emerging digital payment vulnerabilities.
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Key Points:
Acting Comptroller Hsu presents a sophisticated new framework for understanding systemic risk, categorizing threats as "known knowns" (like CRE), "known unknowns" (like cyber risks), and "unknown unknowns" (like quantum computing risks). His emphasis on balancing decisive action with careful analysis, illustrated through the Hellespont metaphor, suggests a shifting regulatory approach that will require banks to demonstrate both proactive risk management and thoughtful restraint.
Risk Data to Geek Out On
Key Points:
Here is a deep dive into the SEC's Division of Examinations priorities for Fiscal Year 2025, which signal a fundamental shift toward comprehensive oversight of technological innovation while maintaining market stability.
Banks face immediate pressure to enhance their digital infrastructure, particularly around AI governance, cybersecurity, and T+1 settlement capabilities. The regulatory focus on operational resilience and third-party risk management may require significant investments in technology and risk management frameworks.
Fiduciary Duty and Compliance
Focus Area | Key Components | Examination Elements |
---|---|---|
Investment Advice | • High-cost products | • Interest rate sensitivity |
Dual Registrants | • Conflict assessment | • Affiliated broker-dealer relationships |
Compliance Programs | • Marketing | • Trading practices |
Private Fund Scrutiny
Focus Area | Key Components | Examination Elements |
---|---|---|
Disclosures and Fiduciary Duty | • Practice alignment | • Interest rate fluctuations |
Fees and Expenses | • Fee calculation accuracy | • Fund-level review |
Conflicts of Interest | • Disclosure evaluation | • Debt usage |
Rule Compliance | • Form PF amendments | • Implementation review |
Regulation Best Interest and Form CRS
Focus Area | Key Components | Examination Elements |
---|---|---|
Recommendations | • Complex products | • Customer best interest |
Conflicts of Interest | • Disclosure review | • Identification procedures |
Form CRS | • Content assessment | • Service descriptions |
Information Security and Operational Resiliency
Focus Area | Key Components | Examination Elements |
---|---|---|
Cybersecurity | • Policy review | • Governance practices |
Data Protection | • S-ID compliance | • Customer records |
T+1 Settlement | • Preparedness evaluation | • Implementation readiness |
Emerging Technologies and Crypto Assets
Focus Area | Key Components | Examination Elements |
---|---|---|
Digital Engagement | • Automated tools | • Trading algorithms |
Crypto Services | • Standards of conduct | • Risk disclosures |
AML and Sanctions Compliance
Focus Area | Key Components | Examination Elements |
---|---|---|
AML Programs | • Business model tailoring | • Program customization |
Customer Identification | • Program evaluation | • Entity verification |
Reporting and Compliance | • SAR filing obligations | • Monitoring systems |
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Thank you for reading,
Naeem
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