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First Bank of Delaware

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On 11/16/2012, the FDIC and FinCEN announced the assessment of concurrent CMPs of $15 million against the bank, for violations of the BSA and AML laws and regulations. The bank also settled civil charges on related activities brought by the Justice Department. All penalties will be satisfied by a single $15 million payment to Treasury.

The FDIC and FinCEN determined that the bank failed to implement an effective BSA/AML Compliance Program with internal controls reasonably designed to detect and report evidence of money laundering and other suspicious activity. Specifically, the bank failed to adequately oversee third-party payment processor relationships and related products and services in a manner commensurate with associated risks. The civil money penalty is the result of the bank's history of noncompliance with laws and regulations and its numerous violations of the BSA.

“To make money, First Bank of Delaware entered into risky lines of business and chose to disregard its Bank Secrecy Act responsibilities,” said FinCEN Director Jennifer Shasky Calvery. “As a result of its failure to implement systems and controls to identify and report suspicious activities, as required by the BSA, financial predators were able to victimize consumers.”

One of the bank's services cited in the FinCEN CMP Order was a Remotely Created Check (RCC) service operated by five third party payment processors. The bank failed to adequately monitor and control excessive unauthorized returns of RCCs deposited through the service. The bank also had major ACH merchant clients, one of which ran almost $22 million in ACH transactions for a foreign-based MSB in the business of "facilitating banking transactions."

On November 16, 2012, Bryn Mawr Trust Company, Bryn Mawr, Pennsylvania, purchased certain assets and assumed deposit liabilities from the First Bank of Delaware. The Delaware Office of State Bank Commissioner terminated First Bank of Delaware's charter and the FDIC terminated its deposit insurance.

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