This was in "Top Stories" on the 15th, but hasn't been discussed here.

FinCEN CMP Assessment

DOJ press release

OCC press release with links to consent order and 2015 C & D

As ever, the C&D describes what the bank was required to do in the future. Also as ever, the penalty assessment, like an indictment, is a one sided but more detailed analysis of the bank's previous actions going back several years.

There are always lessons for other banks to learn from these public crucifixions. However, as the years pass I'm increasingly focused on fate of the individuals involved. In this instance, some of those individuals still have careers because they left a paper trail indicating their concern over their employer's practices and suggesting remedial action.

My favorite example is the Power Point presentation that got edited to remove criticisms before it was shown internally...someone must have kept a copy of the original. That's smart.

From page 11 of this penalty assessment: "During that time, U.S. Bank had AML leadership that failed to actively support compliance efforts, manage and mitigate BSA deficiencies, and ensure that risk mitigation were not compromised by revenue interests."

From page 2 of FIN-2014-A007: “An institution’s interest in revenue should not compromise efforts to effectively manage and mitigate BSA/AML deficiencies and risks, including submission of appropriate and accurate reports to FinCEN.”

First clear cross reference to the "Compliance Culture" document I've noticed in any regulatory action...

My $12 Billion has more staff then US Bank. Who knew? The consultants are going to get rich off of this one.