National Bank Fined $100 Million for BSA/AML Deficiencies

The OCC announced a $100 million civil money penalty assessed against a national bank for deficiencies related to its BSA/AML program, after finding the bank failed to timely comply with a 2015 consent order.

The original 2015 consent order stated that the bank’s BSA/AML compliance program lacked adequate internal controls.  Among other issues, the OCC cited: the lack of an enterprise-wide BSA/AML risk assessment; systemic deficiencies in transaction monitoring related to remote deposit capture services; and the failure to file significant volumes of Suspicious Activity Reports (SARs).  The consent order also stated that the “Bank has begun corrective action, and has committed to taking all necessary and appropriate steps to remedy the deficiencies identified by the OCC, and to enhance the Bank’s BSA/AML compliance program.”

The new consent order, announced on October 23, 2018, found that the bank failed to timely comply with the 2015 consent order.  The new consent order stated that the bank conducted additional look backs as required by the 2015 consent order, and as a result, had to file additional SARs.  The new consent order also stated that the bank initiated wire transfer transactions with inadequate or incomplete information required by regulations promulgated under the BSA, commonly referred to as the “Travel Rule.” The Travel Rule requires financial institutions to include certain customer-identifying information in all transmittal orders in the amount of $3,000 or more.

The OCC’s press release contains links to both consent orders.