After uncovering foreign exchange losses in its U.S. banking subsidiary, Allfirst Financial Inc.,
Allied Irish Bank in 2002 engaged Promontory to conduct an internal investigation. Promontory issued the "Ludwig Report", on March 14, 2002. The report detailed how the trader
John Rusnak hid losses of $691 million over five years. The report concluded that Rusnak, who was fired for his role in the trading losses, received no active help from within or outside the bank. Promontory found that the internal control mechanisms and audits had been insufficient. Promontory advised further the government of the United States and from other countries like
Cameroon and
Iceland. Promontory was hired to carry out by order of the
Holy See a comprehensive investigation of all customer contacts of the
Institute for the Works of Religion ( –
IOR), often also called the Vatican bank, on
money laundering guided by former Promontory Europe executives Elizabeth McCaul and Raffaele Cosimo. In the aftermath of the
subprime mortgage crisis, Promontory was one of several consulting firms selected by federal banking regulators to conduct reviews of loan foreclosures initiated by 16 mortgage servicing companies. Promontory reviewed the foreclosure activities of
Bank of America,
PNC Financial Services and
Wells Fargo, encompassing more than 250,000 loan contracts. Promontory was paid $927 million, which led to strong criticism and doubt about the independence of the examination. A hearing was arranged by the
U.S. Senate Banking Committee to assess whether regulators had handed off too much oversight authority to private consulting firms such as Promontory. Promontory was also engaged by
Commonwealth Bank to oversee their Open Advice Review in 2014 and by
Westpac to undertake an independent review into their breach of anti money laundering laws in 2019. == New York State enforcement action ==