Compliance question of the month: March 2026

In a unanimous decision, a Seventh Circuit panel ruled that the FDIC did not violate the Seventh Amendment by adjudicating an enforcement action seeking a prohibition order and civil money penalty.

A unanimous Tenth Circuit panel affirmed the dismissal of a lawsuit challenging the SEC’s enforcement of federal anti-money laundering reporting requirements against an affiliate.

In a unanimous decision, a Second Circuit panel vacated a New York federal court decision ruling that Sjunde AP-Fonden (AP7) lacked prudential standing to pursue securities fraud claims against KPMG and former Signature Bank officers.

Nine states sued the OCC, alleging it exceeded its authority and violated the APA by issuing its Escrow Powers and Preemption Rules.

The court refused to hold Fifth Third Bank liable for the wire fraud because Hegira could not identify any agreed-upon security procedure that the bank handled in a commercially unreasonable manner or failed to follow in good faith.

The Ninth Circuit reversed and remanded, ruling that the LIBOR Act does not require a floating replacement rate and permits a contract’s fixed-rate fallback to serve as a valid benchmark replacement when LIBOR is unavailable.