John Zasada, Compliance Consulting Director, Financial Institutions Group

On Aug. 13, 2020, the Board of Governors of the Federal Reserve System (“Fed”), the Federal Deposit Insurance Corporation (“FDIC”), the National Credit Union Administration (“NCUA”) and the Office of the Comptroller of the Currency (“OCC”) issued a joint statement on enforcement actions for Bank Secrecy Act (BSA) violations.

The 17-page joint statement explains the circumstances under which the agencies will issue cease and desist orders and formal or informal enforcement actions for BSA violations. The joint statement goes into detail on how BSA compliance program failures can result in an enforcement action. There is increased potential of an enforcement action if a financial institution failed to correct a previously reported BSA problem involving substantive deficiencies in one or more of the required components or pillars of the institution’s compliance program. In addition, the joint statement describes how systemic breakdowns in policies, procedures or processes for filing Suspicious Activity Reports (SARs) can result in an enforcement action.

For more information on the BSA requirements, contact Doeren Mayhew’s regulatory compliance specialists.