The US Department of Justice (DOJ) and federal financial regulators announced major public enforcement actions against two large banks with significant international business dealings in February. These enforcement actions resulted in a guilty plea, a deferred prosecution agreement (DPA), and near-record fines and penalties. Both financial institutions failed to comply with Bank Secrecy Act/Anti-Money Laundering (BSA/AML) requirements. They failed, in some instances willfully, to maintain procedures reasonably designed to assure and monitor compliance with the requirements of the BSA, including detecting suspicious activity indicative of money laundering, terrorist financing, and other crimes, and reporting suspicious transactions to the Department of the Treasury (Treasury) through the filing of suspicious activity reports (SARs). In some instances, these deficiencies, along with inadequate controls and lack of strong management and reporting structures, also led to fraudulent reporting to bank regulators regarding money laundering activity.
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