InfoBytes Blog
FDIC releases August enforcement actions
On September 25, the FDIC released a list of administrative enforcement actions taken against banks and individuals in August. During the month, the FDIC issued 13 orders, consisting of “one consent order under 8(b), four orders of prohibition under 8(e), and eight Section 19 orders.” The consent order, issued against a Kansas-based bank, relates to alleged violations of the Bank Secrecy Act (BSA). Among other things, the bank was ordered to (i) terminate all activity related to its foreign financial institution customers, including such activity as funds transfers, remote deposit capture, money service business remittances, Automated Clearing House transfers, and funds transfers to or from any foreign central bank accounts; (ii) establish a directors’ BSA/anti-money laundering (AML) compliance committee; (iii) implement a revised BSA compliance program to address BSA/AML deficiencies, including incorporating internal controls to assure ongoing compliance, as well as training for appropriate personnel; (iv) maintain a BSA/AML internal control structure, including suspicious activity monitoring and reporting, risk assessment, and customer due diligence; (v) contract with a third-party consulting firm to conduct an independent test of the bank’s BSA/AML compliance program; (vi) implement an effective, comprehensive BSA training program for appropriate personnel regarding specific compliance responsibilities; and (vii) conduct a look-back review to ensure certain reportable transactions and suspicious activities were appropriately identified and reported.