On October 23, the OCC issued a consent order assessing a civil money penalty (CMP) against a national bank for deficiencies in the bank’s Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance program. The deficiencies allegedly resulted in violations of the BSA compliance program and suspicious activity reporting (SAR) rules that led to the issuance of a 2015 consent order, violations of the 2015 order, and additional violations of the SAR rule and wire transfer “travel rule.” According to the 2018 order, the bank allegedly, among other things, (i) failed to “timely achieve compliance” with the 2015 order; (ii) failed to file the required additional SARs; and (iii) initiated wire transfer transactions containing inadequate or incomplete information.

Under the terms of the 2018 order, the bank agreed to pay a $100 million CMP. The order notes that the bank has undertaken corrective actions to remedy the identified BSA/AML-related deficiencies and enhance its BSA/AML compliance program.