BSA-AML Examiner School eBook

RECENT AML/CFT VIOLATIONS

• Binance Money Laundering Case and fine

o $4.3 Billion for its failure to implement proper AML controls and for violating sanctions. • TD Bank o Fines were imposed the U.S, Department of Justice’s, Federal Reserve, Office of the Comptroller of the Currency, and the Treasury Department’s Financial Crime Network. Combined fine will be approximately $3.1 billion for the bank’s pervasive and systemic failure to maintain an adequate anti-money laundering (AML) compliance program. • Block Inc., Cash App o $80 million fine and undertake corrective action for violations of the Bank Secrecy Act (BSA) and anti-money laundering (AML) laws that safeguard the financial system from illicit use. o Unique because if was a multistate agreement o Block agreed to pay the assessed penalty to the state agencies, hire an independent consultant to review the comprehensiveness and effectiveness of its BSA/AML program and submit a report to the states within nine months. • Brink’s Global Services USA Inc. o FinCEN fined $37 million over “willful violations” of the Bank Secrecy Act and its implementing regulations in connection with its movement of funds across the Southwest border. Violations included: • Bank of America o OCC issued a cease and desist order for deficiencies related to its Bank Secrecy Act and sanction compliance program. o OCC took this action based on violations and unsafe or unsound practices relating to these programs, including a failure to timely file suspicious activity reports and failure to correct a previously identified deficiency related to its Customer Due Diligence processes. The order also identifies deficiencies in internal controls, governance, independent testing, and training components of the bank’s BSA compliance program. • Failing to register with FinCEN as money services business (MSB) • Failing to develop, implement and maintain an effective AML program • Failing to file suspicious activity reports o First enforcement action against an armored company