Gramm-Leach-Bliley
Financial Services Modernization Act
General Civil Penalty for Failure to Comply
▪ Officers and Directors personally liable for not more than $10,000 for each violation
▪ The financial institution liable for penalties not to exceed $100,000 for each violation
Criminal Penalties
▪ Fines in accordance with Title 18 of the United States Code, imprisonment for not more than 5 years, or both
▪ Where a violation occurs while violating another federal law, or as part of a pattern of any illegal activity involving more than $100,000 within a 12 month period, fines of up to twice the amount provided in Title 18 of the USC and imprisonment for more than
10 years, or both
FDIC Sanctions (specified in Section 8 of the FDIC)
▪ Termination of FDIC insurance
▪ Cease and Desist Orders barring policies or practices deemed in violation of the:
Act’s Privacy Provisions
▪ Removal of management, directors, officers etc. and potentially barring them, permanently, from working in the banking industry
▪ Fines of up to $1,000,000 for an individual or the lesser of $1,000,000 or 1% of the total assets of the financial institution |