I am still catching up on today's posts. If it hasn't been posted here yet, a $21.6M penalty on SARs.

KPMG

FinCEN agreement

I saw this in the briefing today, but hadn't gotten around it reading it yet. $21.6mm seemingly for failure to file a single SAR!

More than one. The agreement has some good info. I started reading it but ran out of time. I'm sure there'll be more info to come.

I haven't looked at today's BOL briefings yet. I hope it has some good info. It is these articles that cause the pendulum to swing back toward emphasis on compliance.

From an ABA listserv:

The government announced that the action is based, in part, on one series of transactions where an individual deposited approximately $20 million in cash into a Banco Popular account from June 1995 to March 1998. Deposits were made to the account by that individual and employees of Phone Home - a phone card, long distance and money transmission service - "often in paper bags or gym bags filled with small-denomination bills."

Ok- I just read the full version. You are right, there was alot more than one! I think the part that gets me the most is that the tellers repeatedly raised their suspicions to the appropriate operations staff, yet SARs still were not filed!

If top management knew what was going on, this could have been the first Annunzio-Wylie "death penalty" case.

Here is a new article on another fine from a bank in San Antonio.

Broadway Bank Article

Sort of makes you wonder how bad it's got to get before you get hit with the BSA death penalty - loss of charter, doesn't it?

I wondered the same thing, Jim. These are egregious cases, yet the penalties are not particularly harsh, considering the circumstances.

The Broadway case was noteworthy because the bank pleaded guilty to criminal violations -- and the government is trying to determine whether to prosecute individual officers or employees. In both these two cases, however, the real lesson I take away is:

FOR HEAVEN'S SAKE! IF YOUR EMPLOYEES START COMPLAINING BECAUSE YOUR CUSTOMER IS DEPOSITING AN EXCESSIVE AMOUNT OF CASH -- WAGGING IT IN IN PAPER SACKS AND GYM BAGS, YOU NEED TO BE DAMN SURE THE SOURCE OF THE CASH IS LEGITIMATE, OR FILE SARs that are timely, complete, and properly descriptive.

I said this was the Broadway Bank in San Antonio. That may not be the case. I believe this one is from Manhattan.

I wouldn't say Broadway's charter is out of danger quite yet. Since none of the agencies have been through a BSA execution before, they will be making it up as the first one is processed.

This is Broadway in NYC. Their conduct was particularly bizarre. They had been warned several times and still did nothing.