On 4/5/2012, the OCC issued a press release announcing that it issued on 4/4/12 a cease and desist order against Citibank, N.A. for violations of the Bank Secrecy Act and underlying regulations. According to the OCC, the order requires the bank to take comprehensive corrective actions to improve its BSA compliance program.
The compliance program alledgedly had deficiencies with respect to internal controls, customer due diligence, the independent BSA and anti-money laundering audit function, monitoring of its remote deposit capture and international cash letter instrument processing in connection with foreign correspondent banking, and suspicious activity reporting related to that monitoring. These findings resulted in violations by the bank of statutory and regulatory requirements to maintain an adequate BSA compliance program, file suspicious activity reports, and conduct appropriate due diligence on foreign correspondent accounts.
As part of the Order, the bank is required to arrange for an independent look-back for suspicious activity covering areas (and presumably time-frames) to be designated by the bank's Examiner-in-Charge.