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Financial Services Law Insights and Observations

FDIC Orders Maryland-Based Bank to Improve Its BSA/AML Compliance Program

FDIC Anti-Money Laundering Bank Secrecy Act Bank Compliance

Consumer Finance

On December 24, a Maryland-based bank entered into an FDIC consent order involving alleged deficiencies in its BSA/AML compliance program. The consent order requires that the bank’s board of directors increase its oversight of the bank’s BSA compliance program. In addition, under the consent order, the bank must (i) appoint a qualified BSA officer and (ii) conduct a retrospective review of currency transaction reports beginning in May 2013 until the effective date of the consent order to determine whether transactions were properly identified and reported.