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Former private banker banned and fined $100K for AML violations

Miami, FL
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The OCC issued a consent order to Dirceu P. Magalhaes, former private banking senior manager for Royal Bank of Canada, Miami Federal Branch (now closed), Miami, Florida. Magalhaes was prohibited from future participation in any manner in a U.S. financial institution of any kind, and ordered to pay a civil money penalty of $100,000.

The OCC found that—

  1. during 11 months in 2013, Magalhaes facilitated transactions where he helped his clients and others make international money transfers between Brazil and the U.S. through an informal network
  2. These transactions were for high risk clients and other individuals residing in a high risk jurisdiction, and the majority of the transactions had no known legal or business purpose, and they avoided record keeping.
  3. Magalhaes did not conduct adequate due diligence on the transactions or on the parties to the transactions.
  4. The Branch policy did not permit Respondent to facilitate these types of transactions.
  5. Magalhaes withheld material information from the Branch regarding his Doleiro [Portuguese: a money changer on the Brazilian black market] activities and, at times, actively concealed this information.
  6. Respondent gained approximately $15,000 from his Doleiro activities.

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