agency or any law enforcement authority. 121. No further action will be taken by the Department against the Bank for the conduct set forth in this Consent Order provided that the Bank complies with the terms of this Consent Order. For the sake of clarity, such conduct includes (a) the Bank's AML control def

nch, and Deutsche Bank Trust Company America (collectively "Deutsche Bank" or the "Bank") have agreed to pay $150 million in penalties as part of a Consent Order entered into with the New York State Department of Financial Services ("DFS" or the "Department") for significant compliance failures in connection