This fine of $315 million is on top of the $250 million previously agreed to, and is a result of BTMU (Bank Tokyo-Mitsubishi UFJ Group) pressuring Price Waterhouse Coopers (PwC) to remove elements from its prior attestation to NY State that would have cast a dimmer view on its behavior.
In addition, the NY Department of Financial Services (DFS) insisted that one employee be fired and that he, and two others working elsewhere in BTMU, be barred from further involvement in the affairs of the NY branch. The hiring of an indepdendent consultant to conduct a program review through March 2015 (with a possible extension of up to September 2016) was also mandated, as was the relocation of the compliance functions to NY.
As the NY DFS doesn't provide any automated way to get its releases, I'm indebted to the FCPA Blog's story on this matter – link below.
Additionally, I've included links to the settlement and BTMU's statement in response to the settlement.
Word to the wise – like the credo for doctors: first do no harm. How much cheaper would it have been for BTMU to fess up in the first place? Much.
Links:
FCPA Blog story
Settlement between NY DFS and BTMU
BTMU Statement