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#376954 - 06/23/05 11:22 PM
Big Bank fails exam
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Anonymous
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#376955 - 06/23/05 11:24 PM
Re: Big Bank fails exam
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Anonymous
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I heard they have created a separate BSA/AML compliance testing section of their audit department.
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#376958 - 06/25/05 06:10 PM
Re: Big Bank fails exam
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Anonymous
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This is unbelievable! Why are they getting away with this?
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#376960 - 06/27/05 05:07 PM
Re: Big Bank fails exam
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10K Club
Joined: Jun 2005
Posts: 10,395
Jersey Shore
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Quote:
This is unbelievable! Why are they getting away with this?
I know it looks like Wells is 'getting off lightly', and that's irritating.
The thing that should be really alarming, though, is that they got the reprimand (or whatever you want to call it) while in the midst of implementing enhanced AML systems and processes. So, there was no allowance/partial credit for already working on the issue.
Feel free to be as aggravated as you want for your own reasons. I plan to be aggravated for a different set of reasons.
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#376961 - 06/28/05 05:39 PM
Re: Big Bank fails exam
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Anonymous
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Explains recent calls from headhunter looking for AML Audit Manager for Wells.
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#376963 - 06/29/05 12:24 AM
Re: Big Bank fails exam
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Power Poster
Joined: Jun 2001
Posts: 8,272
Where the heart is
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Quote:
In my opinion Wells recieved credit for their work on the AML problems by NOT being place on a C&D. It seems that an "informal" was very kind to them and seems unfair to community banks. The headhunters have been very active lately.
Wells received credit, but smaller banks DO NOT receive credit for improvements made or that are being made. If your program has any deficiency, you WILL get a Cease and Desist. At least that's how it is (supposed) to be for National Banks per the OCC's Bulletin #2004-50:
http://www.occ.treas.gov/ftp/bulletin/2004-50.doc
"Unlike other examination areas, a statutory mandate exists that instructs the OCC to issue a cease-and-desist order (C&D) whenever a bank fails to establish and maintain a BSA compliance program, as required by 12 CFR 21.21. This mandate also applies when a bank fails to correct any problem with its BSA compliance program, which was previously cited in a report of examination (ROE) or other supervisory correspondence. Examples in which a violation citation and accompanying C&D are appropriate include situations in which a bank:
• Lacks a BSA compliance program that adequately covers all of the required program elements (internal controls, independent testing, responsible personnel, and training);
• Fails to implement a written BSA compliance program;
• Exhibits BSA compliance program deficiencies coupled with aggravating factors such as highly suspicious activity creating a significant potential for money laundering, potential terrorist financing, a pattern of structuring to evade reporting requirements, insider complicity, repeat failures to file currency transaction reports or suspicious activity reports, or other substantial BSA violations;
• Fails to respond to supervisory warnings concerning BSA compliance program deficiencies previously reported to the bank, or continues a history of program deficiencies, even when deficiencies are dissimilar to those cited in the past;
• Engages in systemic or pervasive BSA reporting or record keeping violations, fails to respond to supervisory warnings regarding such violations, or continues a history of such violations, even when they are dissimilar to those cited in the past; or
• Engages in a one-time, nontechnical violation that demonstrates willful or reckless disregard for the requirements of the BSA or that creates a substantial risk of money laundering or the financing of terrorism. The violation renders deficient an otherwise effective program.
So, if you had a warning about a problem in the past, but fixed that problem, but then had another problem, you get (according to this bulletin) a C&D.
But we all know there are dual standards out there, or if we didn't know that before, we know that now!
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'
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#376964 - 06/29/05 01:08 PM
Re: Big Bank fails exam
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Power Poster
Joined: Jul 2003
Posts: 2,675
Austin Texas
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Bonnie, That's called PAC, and I'm sure WF has a pretty active and well-funded one!
_________________________
My comments are absolutely no reflection of, nor influenced by, my employer - take them at your own risk.
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#376965 - 06/29/05 03:33 PM
Re: Big Bank fails exam
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Anonymous
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Thats called PAC? I don't get it...course it is humpday, so I am on the downward spiral 
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#376966 - 06/29/05 03:52 PM
Re: Big Bank fails exam
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Power Poster
Joined: Jul 2003
Posts: 2,675
Austin Texas
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Political Action Committees - they likely have their own lobbyists, or contribute heavily to campaign funds of 'friendly' political candidates!
_________________________
My comments are absolutely no reflection of, nor influenced by, my employer - take them at your own risk.
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