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.
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