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Banker's Toolbox solidifies its position as the premier solution for fast-growing financial institutions with the release of BAM+ 4.0 upgrade.
Banker's Toolbox continues to lead the BSA/AML and Fraud prevention marketplace with the release of BAM+ 4.0. This solution provides increased detection with more versatility, transparency and control. BAM+ 4.0 also boasts a new customer due diligence platform, Due Diligence Manager, which will keep institutions compliant with the impending beneficial ownership mandates. (Read full press release here.)

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New Venezuela Executive Order and general licenses

OFAC has announced that the president has issued a new Executive Order, "Imposing Additional Sanctions with Respect to the Situation in Venezuela," and that there were four new Venezuela-related general licenses issued to allow certain transactions that would otherwise violate that Order. See our OFAC Update for details. UPDATE: The Executive Order was published on 8/29/2017 as E.O. 13808.


FDIC lists July enforcement actions

The FDIC has released a list of orders of administrative enforcement actions taken against banks and individuals in July. There was a total of 24 orders. The administrative enforcement actions in those orders consisted of three consent orders; seven removal and prohibition orders; four Section 19 orders; three civil money penalties; and seven terminations of consent orders.

The civil money penalties were assessed against individuals formerly affiliated with banks in Oklahoma ($125,000), Pennsylvania ($35,000) and Kentucky ($35,000) for unspecified reasons. Each of those individuals also received a removal/prohibition order. Four additional removal/prohibition orders were issued to individuals formerly affiliated with banks in Oklahoma (2 individuals), Missouri, and Illinois.


OCC schedules Indiana workshops

The OCC has announced it will host two workshops at the Indianapolis Marriott East on September 26–27, for directors of national community banks and federal savings associations.

  • The Risk Governance workshop on September 26 combines lectures, discussion, and exercises to provide practical information for directors to effectively measure and manage risks. The workshop also focuses on the OCC’s approach to risk-based supervision and major risks in the financial industry.
  • The Credit Risk workshop on September 27 focuses on credit risk within the loan portfolio, such as identifying trends and recognizing problems. The workshop also covers the roles of the board and management, how to stay informed of changes in credit risk, and how to effect change.


Singapore company pays $415K for Iran violations

COSL Singapore Ltd, an oilfield services company located in Singapore, has agreed to pay OFAC $415,350 to settle potential civil liability for 55 apparent violations of the Iranian Transactions and Sanctions Regulations. For details, see our Penalty page.


FinCEN issues more targeting orders

FinCEN has announced it has issued revised Geographic Targeting Orders (GTOs) covering certain "all cash" high-end residential real estate purchase activity from September 22, 2017, through March 20, 2018, inclusive. The order requires title insurance companies and their subsidiaries and agents to file specially-completed Form 8300 reports for a residential real estate purchase by a legal entity without a bank loan or similar external financing, made in whole or in part with currency, a cashier's check, a certified check, a traveler's check, a personal check, a business check, or any form of money order, or a funds transfer. Reportable purchases will be those for a total purchase price designated trigger amounts or more in—

  • Bexar County, Texas ($500,000 or more);
  • County of Miami-Dade, Broward or Palm Beach in Florida ($1 million or more);
  • Borough of Brooklyn, Queens, Bronx, or Staten Island, New York City ($1.5 million or more);
  • County of San Diego, Los Angeles, San Francisco, San Mateo or Santa Clara, California ($2 million or more);
  • Borough of Manhattan, New York City, or City and County of Honolulu, Hawaii ($3 million or more).

FinCEN also published Advisory FIN-2017-A003 to provide financial institutions and the real estate industry with information on the money laundering risks associated with real estate transactions, including those involving luxury property purchased through shell companies, particularly when conducted without traditional financing. Such transactions are vulnerable to abuse by criminals seeking to launder illegal proceeds and mask their identities. The Advisory provides information on how to detect and report these transactions to FinCEN.

From information obtained during earlier impositions of similar GTOs, FinCEN learned that about 30 percent of reported transactions involved a beneficial owner or purchaser representative (for the purchasing entity) that was also the subject of a previous suspicious activity report. An FAQ on the GTOs was also released.


Federal Reserve issues C&D to Texas bank

The Federal Reserve Board and the Texas Department of Savings and Mortgage Lending have issued a Consent Cease and Desist Order to The Bank & Trust, S.S.B., of Del Rio, Texas, following a joint examination of the bank in which the Board and Department identified "significant deficiencies in the Bank’s risk management and compliance with applicable laws, rules, and regulations relating to anti-money laundering (“AML”), including the Bank Secrecy Act; the rules and regulations issued thereunder by the U.S. Department of the Treasury; and the AML requirements of Regulation H of the Board."


OFAC targets supporters of North Korean regime

Treasury's Office of Foreign Assets Control announced on Tuesday it has designated ten entities and six individuals in response to North Korea’s ongoing development of weapons of mass destruction (WMD), violations of United Nations (UN) Security Council Resolutions, and attempted evasion of U.S. sanctions. The new designations target third-country companies and individuals that assist already-designated persons who support North Korea’s nuclear and ballistic missile programs; deal in the North Korean energy trade; facilitate its exportation of workers; and enable sanctioned North Korean entities to access the U.S. and international financial systems.

As a result of Tuesday’s action, any property or interests in property of the designated persons in the possession or control of U.S. persons or within the United States must be blocked, and U.S. persons are generally prohibited from dealing with them. For identification of the new designations, along with a number of removals from and updates to the OFAC SDN lists, see our OFAC Update.


Two terrorists added to SDN List

OFAC has designated two individuals and added them to its SDN List as Specially Designated Global Terrorists with links to the Islamic State of Iraq and the Levant (ISIL). For identification details, see our OFAC Update.


U.S. shipping company pays $518K OFAC penalty

OFAC has reported that Blue Sky Blue Sea, Inc., doing business as American Export Lines and International Shipping Company (USA), of Los Angeles, California, has agreed to pay $518,063 to settle potential civil liability for 140 apparent violations of the Iranian Transactions and Sanctions Regulations during 2012. According to OFAC the company did not self-report the apparently non-egregious violations. For further information, see our Penalty page.


FTC charges marketers with theft of over $40 milllion

The Federal Trade Commission has charged Hornbeam Special Situations LLC and affiliated entities and individuals with duping consumers into thinking they were applying for loans, then using the consumers' bank account information to issue unauthorized electronic remotely created checks (RCCs) to debit those consumer's accounts for a monthly coupon service that involved monthly fees. The FTC alleges that the defendants used the RCCs to withdraw from consumers’ accounts an initial fee ranging from $49.89 to $99.49, and recurring monthly fees of $14 to $19.95.

The defendants in this case are EDebitPay LLC; Dale Paul Cleveland; William Wilson; Keith Merrill; clickXchange Media LLC; Platinum Online Group LLC, doing business as Premier Membership Clubs; Hornbeam; Cardinal Points Holding LLC; Cardinal Points Management LLC, doing business as Clear Compass Digital Group; Gyroscope Management Holdings LLC; Jerry L. Robinson; Earl G. Robinson; James McCarter; Mark Ward; iStream Financial Services Inc.; Kris Axberg; Richard Joachim; and Chet Andrews.

The FTC charged all of the defendants with violating the FTC Act. The Commission also charged the EDP and Hornbeam defendants with violating the Restore Online Shoppers’ Confidence Act. In addition, the FTC charged defendants, except for Mark Ward, with violating the Telemarketing Sales Rule.


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