Answer by Andy Zavoina:
This is from a list of penalties I assembled some time ago.
Bank Secrecy Act
- Civil penalties for each willful violation of CTR reporting requirements the greater of $25,000 or the amount of the CTR (not to exceed $100,000)
- Criminal penalties up to ten years in jail and $500,000 fine
- $1,500 per report for other reporting or recordkeeping violations such as filing an incorrect CTR
- $500 for negligent violation of any BSA requirement
- Loss of Bank charter is possible in extreme cases
Answer by Richard Insley:
Although these penalties haven't been imposed as frequently as they were in the pre-SAR days, they're the reason BSA is always risk-rated at the top of most banks' list of priorities. As you decide how to deploy scarce risk management resources, it's easy to determine how much to spend on CTR compliance. Simply take the number of CTRs you file each year, multiply by $25,000, throw in the damage to your reputation plus the opportunity cost of the year your boss might spend at Club Fed...AND THERE YOU HAVE IT--you pay whatever it costs to implement a zero-tolerance CTR compliance program!
First published on BankersOnline.com 3/11/02