I am continually amazed when a small community bank starts asking about how to manage opening an account for an offshore company or some other activity that they have absolutely no resources or knowledge to properly manage because someone on senior management thinks it is a good idea.

Well FinCEN finally said this also:

“When a small institution opens its doors to the world, takes on greater risks than it can manage, and puts profits before AML controls, bad actors are bound to take advantage,” said FinCEN Director Jennifer Shasky Calvery.

She was talking about a small credit union with $4 million in assets and only five employees that they just slapped with a $300,000 fine.

http://www.fincen.gov/news_room/nr/pdf/20141125.pdf

I was just reading that article. I'm surprised that they didn't get slapped with more or ordered to close their doors. 90% of their income was derived from those offshore MSBs. Can anyone spell 'red flag'?

From 2009 through 2014, North Dade had significant deficiencies in all aspects of its AML program, including its internal controls, independent testing, training, and failure to designate an appropriate BSA compliance officer.

And exactly where was the NCUA during this period???? No where like usual. At some point of time, someone needs to figure out that the current NCUA examination system is terribly broken.

NCUA did hit them with a C&D last year for this activity. But apparently the quintet of employees at the CU didn't take it very seriously.

Major case of the tail of a Great Dane wagging the body of a Chihuahua.

I'm linking Saddle River's penalty assessment from last year only for the convenience of the BSA officer who might find this thread and attempt to convince management:

These people with their unimaginable dollar amounts and extraordinary fees are not coming to us because they think we're smart. They are here because they think we are stupid!

Heck, this was more like painting a bull's eye on their back and yelling, "Shoot me!"

It should also be noted that as of March 31, 2014 Saddle River Valley Bank was voluntarily liquidated and closed.

As I read the CU's last call report, equity was about $480,000. Now, subtract a $300,000 penalty...

My opinion is that the FDIC would have arranged for a P & A on the day the FinCEN order was published.

Not at all surprising that it was a Credit Union. Most of the CU industry really has not yet felt the full pain and burden of BSA. I know of a few that are still in denial of how serious it is.

Then again, the stuff that I have seen the NCUA cite in a BSA exam reminds me of the stuff Banks got cited for prior to 2000. Mainly form over substance.