OFAC is contemplating the idea of fining bankers for violations.

US to Hold Bankers Responsible

why do i picture the little guy left holding the ball, while upper management gets away scott free?

Yes Happy, the little guy who tried his best to get it done the right way, and in some cases the legal way, to begin with but couldnt because of the push back from upper or sr mgt.

Forecast: More CYA memos to file; increased SAR reporting on insiders; increase in job-hunting BSA officers.

Again, the regulators have the power to remove individuals from banking permanently. All rattling the sabre does is put nicks in the blade. They need to shut up and do something. If a couple of those million dollar a year execs at HSBC were barred from working for a U.S. chartered institution, CEOs might start to listen to the people they hired to carry out BSA or OFAC related responsibilities.

The CEOs will not "listen to the people they hired to carry out BSA or OFAC related responsibilities" as those people will be the ones barred. The million dollar execs will keep on causing trouble.

As the responsibility is conditioned on listening, I'm counting on a paper trail that leads to the people who made the decisions. If there is none, then the responsibility will come to rest on the right people either way.

I wish i caould be one of those "couple of million dollars per year" executives...it would only take a year or two and i'd be in my own self-imposed retirement

Thought some of you might be interested in this article.

Compliance Fails - Go to Jail

Should be required reading as part of the BSA/AML training of board members and senior management.

I agree, I think I will print that article and hand it our to the Board of Directors at the next meeting.

This will be annoying:

"Filing an extremely low number of Suspicious Activity Reports (as required by the BSA) in relation to other comparably-sized institutions;"

Perhaps someone should supply them with a copy of the BSA/AML Examination Manual:

Examiners should not criticize a bank solely because the number of SARs or CTRs filed is lower than SARs or CTRs filed by “peer” banks.

I've heard this story before. I'll believe it when I see a CEO or board member perp walked down Wall Street.