This seems to be the year for BSA enforcement cases. The latest (as of our date of publication, mind you) is an agreement between the Federal Reserve Bank of San Francisco and County Bank, Merced, CA. Like most of the other BSA enforcement cases, this one is based on compliance program failures.
The agreement requires County Bank to develop an acceptable written program. The program must include procedures to identify transactions and situations covered by the BSA. The consent also calls for a risk focused assessment of the Bank's customer base and enhanced due diligence as appropriate. In addition, the bank must conduct an independent audit and place internal controls. In short, the requirements make a pretty good description of a BSA program.
In the context of the FinCEN Director's comments about defensive SAR filing or weak programs, this case clearly is based on program weaknesses rather than a judgement that not enough SARs were filed.
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