On Oct. 10, 2019, the Financial Crimes Enforcement Network (FinCEN) announced it adjusted for inflation the civil money penalties (CMPs) for violations of the Bank Secrecy Act (BSA). This serves as an important reminder that federal examiners review BSA compliance to a deeper level than even just a few years ago and noncompliance can be very costly. Negligent violations by financial institutions result in a maximum penalty of $1,146, while a pattern of negligent activity goes up to a maximum penalty of $89,170. Willful violations of the BSA result in maximum penalties ranging from $57,317 to $229,269. Violations of certain due diligence requirements can result in penalties all the way up to $1,424,088. Even violations related to funds transfer recordkeeping result in penalties of up to $21,039. All these adjusted penalties are in effect for violations occurring after Oct. 10, 2019.


John Zasada, JD, CAMS – Compliance Consulting Director, Financial Institutions Group. John can be reached at zasada@doeren.com.