The Bank shall permanently install personnel within its New York branch to oversee andaudit any offshore money-laundering due diligence andmonitoring undertaken by the Bank.
They must now personally sign off on financial reports, comply with Sarbanes-Oxley's requirements for internal monitoring, work with the board's audit committee and the company's internal auditors.
At the very least, KPMG is almost certainly going to have to return the audit fees, amounting to tens of millions of dollars, and the firm may be liable for other damages if the courts determine that the firm was in any way derelict in monitoringand supervising Mr. London, who was in charge of some 50 audit partners and 500 employees.