What are everyone's thoughts on FinCen's recent $8million civil money penalty against Community Bank of Texas? Will you be doing anything differently in your BSA compliance programs due to this?
the bigger question should be how does this impact your bank and what will your bank be doing differently, if anything. trying to compare to what another bank is or isn't doing is not always an apple to apple comparison.
This is a pretty significant lack of procedures this bank admitted to:
CBOT admitted that it willfully failed to implement and maintain an effective anti-money laundering (AML) program that was reasonably designed to guard against money laundering. CBOT also admitted that it willfully failed to report hundreds of suspicious transactions to FinCEN involving illegal financial activity by its customers and processed by, at, or through the bank even after the bank became aware that certain customers were subjects of criminal investigations. The violations occurred from at least 2015 through 2019 and caused millions of dollars in suspicious transactions to go unreported to FinCEN in a timely and accurate manner, including transactions connected to tax evasion, illegal gambling, money laundering, and other financial crimes.