FDIC, Maryland OCFR Joint Order Requires Bank to Improve AML/CFT Program

A Maryland-based bank recently agreed to a consent order with the FDIC and Maryland Office of the Commissioner of Financial Regulation (OCFR) to improve the bank’s Anti-Money Laundering/Countering the Financing of Terrorism Program (AML/CFT Program). The consent order addresses certain deficiencies in the bank’s AML/CFT Program identified by the FDIC and OCFR in March 2022.

The consent order—under which the bank neither admits nor denies the allegations—requires the bank’s board of directors to assume full responsibility for the development, approval, and implementation of new AML/CFT policies and procedures. Among these new policies is the establishment of a compliance committee and the hiring of a permanent AML/CFT Officer with direct-reporting responsibilities to the board.

The consent order also requires the bank to do the following:

• prepare a risk assessment within 30 days;
• institute a system of AML/CFT internal controls within 90 days;
• conduct a comprehensive review within 120 days;
• undergo independent testing within 150 days;
• train appropriate personnel in all relevant aspects of the Bank Secrecy Act and AML/CFT programs; and
• periodically submit an action plan to address all identified weaknesses to the compliance committee.