Learning from Others: BSA Penalties
John S. Burnett, BOL Guru
Tip: Make a note to click on the Email This Article link at the top of the page, and forward it to the individual(s) at your institution who are responsible for day-to-day compliance with Bank Secrecy Act regulations, or for training staff members on your BSA and anti-money laundering policies and procedures.
A New BankersOnline Resource
One of the most difficult BSA-related tasks is that of dispelling the "it can't happen to us" feeling. One of the successful strategies for instilling a sense of the significance of BSA and AML requirements is relating the real-world cases of banks that have been penalized -- some quite harshly -- for their failure to take seriously enough the risks of non-compliance.
In BOL's new BSA Monetary Penalties List, we have collected descriptions of all of the publicized FinCEN Civil Money Penalty Orders from 2004 to the present, plus similar orders from other regulators. Each entry includes:
- a summary of the principal problems cited in the Order,
- a link to the original document for further investigation,
- the amount of the penalty, and, where available,
- the institution's total assets as reported just prior to the Order.
We've included Orders against non-bank financial institutions (MSBs and casinos, for example), and individuals, too, when they showed potential as object lessons for bank staff or customers.
Executive Steps:
- Take a look at our new BSA Monetary Penalties List.
- Read one or two of the actual CMP Orders linked in the list. The Orders tend to be concise, at a few double-spaced pages each.
- Remember to email this article to key people in your organization.
- Know that you've put another effective tool into the hands of your institution's BSA/AML compliance coordinator.
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First published on BankersOnline.com 3/8/07
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