Call me crazy, but this looks somewhat familar....?

http://www.occ.gov/ftp/release/2010-121a.pdf

I smell new job openings in McLean, VA for BSA compliance professionals...

Isn't that where the CIA headquarters is?

Not so loud

PS

If there was any truth to the incinuation do you think there would be a C&D.

I thought that was Langley?

Langley is a community within McLean.

There are some pretty unique aspects to this C&D, though. When was the last time you saw PEPs mentioned in a C&D? (just to pick one)

The last time I went to Miami....

Wasn't HSBC one of the first banks back in 2001 or 2002 to get whacked by someone for something AML/BSA stuff?

I was surprised that the OCC wants to be informed (possibly approve?) of the new BSA Officer and Regional Compliance Officer. That is dangerous territory.

You read that right, the OCC has reserved the right to approve/veto the new BSA Officer and Regional Compliance Officer.

From what I got they do not want to approve but would veto a candidate.

Yes, they can veto but a failure to veto is not to be considered an endorsement. That way, if there is a problem later on, no can say "well, you approved this person."

Fun times.

"Approval" language is relatively common in enforcement actions where a bank is directed to hire new personnel or even consultants. The regulator does not want them bringing in someone who they do not believe is capable of doing the job; i.e. leading the bank out of the wilderness. As noted, the agency does not approve the nominee, but they can certainly refuse to approve...

I haven't read the order yet, but PEPs might have come up because, if I recall correctly, they took over the foreign embassy business from Riggs Bank way back when. Anyone feel free to correct this if I am mistaken.

They bought Wachovia's embassy business in 2005.

I guess the business cards of those who got jobs under those circumstances would say "Not Endorsed by Regulators, but Not Rejected Either"

Wachovia bought it from Riggs.