I appear to be completely Google-inefficient today. I can't find instances online where banks have been fined for violations of CIP.

The reason I'm looking is because I have an employee at my bank who seems to think CIP is just too much of a hassle. While her opinion doesn't matter and she will be overridden anyway, I want to put the fear of FinCEN in her and show her what has happened to other institutions. Help?

Thanks in advance. My Google-fu has failed me today.

If I may be so bold, grab the tiger by the head, not the tail. CIP is part of her job, (pull job description if needed), so her fear of FINCEn is irrelevant. If she offers resistance to doing her job, write her up/probation. Add that this will continue until she completes her responsibilities or it will be deemed that her termination will be the ultimate result. Harsh, but BSA related regs are no place for fooling around with "hassle" issues on the part of an obstinate employee. Good luck. Hopefully she will listen and learn prior to being written up....

I agree, to be honest. She's understanding that CIP must be followed, but I guess it's one of those things where I sort of want the nail in the coffin, so to speak. "See? See what can happen???" LOL. Like a mother explaining to look both ways before crossing the street...

I think you would look for references to BSA "progam" violations and deficiencies.

I would hope that all banks, prior to formal CIP, took appropriate steps to know who they were doing business with in order to mitigate fraud risk. It's common sense - Banking 101. If she doesn't get something this basic, maybe she doesn't need to be working in such a high risk business.

You'd think so... but we acquired a bank that failed, and maybe there's a reason it failed. I remain amazed at how often I hear lenders and bankers trying to worm out of basic CIP requirements. It blows the mind!

The rules are so very specific now, we're in a different world. We use some of our periodic newsletters to keep CIP fresh in the minds of our staff with puzzles, tips & techniques, etc. Some of the frontline staffs have alot of turnover, so it can be a challenge to keep everyone up to speed on the do's and don'ts.

Thanks for the link Ed! That may come in handy.

BSA/AML Penalties List

http://www.bankersonline.com/security/bsapenaltylist.html

Thanks for the updates!!!