Bank Agrees to $613 Million Settlement Over Failings of Anti-Money Laundering Program

On February 15, 2018, a national bank agreed to pay $613 million because of its failure to implement an effective anti-money laundering program, and because of its failure to report suspicious transactions.

As part of a deferred prosecution agreement with the U.S. Department of Justice, the bank admitted that it had willfully failed to implement an effective anti-money laundering program, and that it had failed to report suspicious transactions as required by the Secretary of Treasury.  The bank admitted that its anti-money laundering staff capped the number of alerts its automated monitoring system would report, so that it only identified a certain number of transactions for further investigation.  This caused the bank to ignore and fail to investigate thousands of suspicious transactions.

In addition, the bank willfully failed to report suspicious banking activities of one of its customers, despite being on notice that the customer was using the bank to launder over $2 billion from an illegal payday lending scheme.

The bank will pay $453 million to the Justice Department; $15 million to the Fed, $75 million to the OCC, and $70 million to FinCEN.

The deferred prosecution agreement is available here: https://www.justice.gov/usao-sdny/press-release/file/1035081/download.