OCC Takes Enforcement Action Against Bank on AML Deficiencies

The OCC recently entered into a Formal Agreement with a large national bank to address deficiencies in the bank’s financial crimes risk management practices and anti-money laundering internal controls.

The Formal Agreement requires the bank to take corrective actions, including:

• maintaining a Compliance Committee of independent members of the Board of Directors;
• creating an action plan that enhances the bank’s current practices to comply with the Bank Secrecy Act, Anti-Money Laundering laws, and OFAC Sanctions;
• developing a program to assess and mitigate the BSA/AML and OFAC Sanctions risks of new products, services, or geographic markets;
• enhancing its customer due diligence program to ensure the effective collection and analysis of customer information by all business lines; and
• adopting an enhanced suspicious activity monitoring and reporting program to ensure the timely, appropriate, and effective identification of unusual activity.