Rarely do corporate officers remain with a single employer for their entire careers, and that is true in banking as well. Relationship managers often move to competitors, and naturally they hope that "their" book of business follows them. Most of these bankers play by the rules governing the relationship with their employer, but not all do. A banker's former employer historically has been able to resort to civil litigation for relief when the rules are not followed, usually for money damages (sometimes indemnified by the banker's new employer) but also injunctive relief to recover stolen records. The banker is then free to carry on with his new employer. His former employer is obligated to file a suspicious activity report with the regulators if theft of bank records or other fraud is involved, but the regulatory agency acts on its own, secretly, and oftentimes the bank is left to wonder what, if anything, ever came of it. However, a recent decision from the Board of Governors of the Federal Reserve System enforcing current law demonstrates how severe the penalties can be for bankers who breach obligations owed to their former employer. (Issued March 24, 2021.) Continue reading >