According to the DFS allegations (and other public information):
• State-owned Industrial and Commercial Bank of China has $22 Billion in assets in the New York branch alone, and over $5 Trillion globally, and is the world’s largest bank by assets according to the WSJ and third largest by capitalization according to Forbes.
• ICBC entered into a Cease and Desist with the Federal Reserve Board in 2018 for BSA/AML and OFAC violations, requiring a lookback for suspicious transactions in its correspondent banking business.
• BSA/AML/OFAC deficiencies persisted for several more years through repeated examination cycles, including some identified in a targeted review in 2022.
• ICBC also improperly shared Confidential Supervisory Information (CSI) with an unidentified foreign regulator, concerning information as to whether the New York Branch was the subject of any regulatory investigations.
• Although advised not to share this information without permission from DFS and FRB, staff at the New York Branch disclosed the CSI to an oversees affiliate which then shared it with the foreign regulator.
• In addition, an employee apparently backdated five certificates in KYC files.
• The FRB also penalized ICBC $2.4 million for lacking CSI policies and procedures and for what appears to be the same unauthorized disclosure.