On March 17, the OCC and FinCEN issued civil monetary penalties against a federal savings bank for “willfully” failing to meet minimum compliance program requirements and shoddy suspicious transaction reporting. The consent orders read like a veritable “how not to” for reviewing anti-money laundering alerts.
According to the OCC’s consent order imposing a $60 million civil monetary penalty, between 2017 and 2021, the bank failed to implement and maintain an adequate BSA/AML Compliance Program and failed to correct problems with its program that the OCC previously reported to the bank relating to BSA/AML internal controls.
