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#1872937 - 11/20/13 08:13 PM BSA-AML Penalties
Retread Offline
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On the BOL website where you find the BSA-AML Civil Money Penalties list, it shows that TD Bank was fined $85 million. Does anybody know where that amount came from? The figures don't add up. Most sources indicate that the fines totaled $52.5 million, considering $37.5 million was concurrent, but even without taking that into consideration, the figures don't add up.
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#1873470 - 11/22/13 01:55 PM Re: BSA-AML Penalties Retread
banker1976 Offline
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There is a story from Fox Business citing the fine was $90 million. $37.5 from FinCEN, $37.5 from OCC, and $15 million from SEC.
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#1873509 - 11/22/13 02:54 PM Re: BSA-AML Penalties banker1976
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I saw that but if you read the FinCEN assessment
FinCEN Assessment on page 5, you will see that the $37.5 million from FinCEN and the $37.5 million from OCC would be satisfied by one payment of $37.5 million to Treasury which takes it back to $52.5 million.

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#1873698 - 11/22/13 05:52 PM Re: BSA-AML Penalties Retread
banker1976 Offline
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Oh okay, gotcha.
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#1873864 - 11/22/13 09:51 PM Re: BSA-AML Penalties Retread
John Burnett Offline
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Joined: Oct 2000
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Cape Cod
And you caught me on that one. That TD Bank entry has been corrected. Thank you for letting us know of the error. It was a "copy and paste" slip up.
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#1873888 - 11/22/13 10:11 PM Re: BSA-AML Penalties Retread
el guapo Offline
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Joined: Jul 2004
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Several years ago I got a pretty thorough chastizing for not being a team player from the person I directly reported to when I refused to open accounts (not passing the buck but I don't open accounts as a matter of my job duties) for entities that would be 1)foreign residing in nature (our board approved policy states we only bank US residents) 2)make use of aliases rather than their actual identity 3)provide no data regarding authorized persons 4)exclusively transact in wires coming from and going to foreign sources (we don't need signature if they aren't going to sign anything! wire auths would come by email). When I said that I felt this activity might run afoul of not only our stated policy but also...maybe...some BSA/AML concerns she told me I was ridiculous and challenged me to find one instance in which the above listed activities resulted in any kind of BSA/AML violation. I went to the list referenced in this post and to my suprise (not really) I saw that the very bank she came to us from was found to have violated BSA/AML regulations of the nature that I was now being asked to process and the final report/fine was handed down just months after she left and came to work for us...

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