On June 15, FinCEN announced a $4.5 million civil money penalty against a West Virginia-based bank for alleged violations of the BSA from 2008 through 2013. According to theAssessment of Civil Money Penalty, the bank failed to monitor, detect, and report suspicious activity as a result of an inadequate AML and customer due diligence program, ultimately allowing over $9.2 million in structured and otherwise suspicious cash transactions to pass though the financial institution unreported. FinCEN found that the bank failed to establish and maintain an AML program that provided, at a minimum: (i) a system of internal controls to ensure ongoing compliance; (ii) a designated individual or individuals responsible for coordinating and monitoring day-to-day compliance; (iii) independent testing for compliance to be conducted by either an outside party or bank personnel; and (iv) training for appropriate personnel. FinCEN’s enforcement action and $4.5 million civil money penalty against the bank is concurrent with a $3.5 million penalty imposed by the FDIC, of which $2.2 million is concurrent with a forfeiture pursuant to a deferred prosecution agreement with the U.S. Attorney’s Office for the Southern District of West Virginia.