John Zasada, Compliance Consulting Director, Financial Institutions Group

On Dec.16, 2021, the Office of the Comptroller of the Currency (OCC) and the Financial Crimes Enforcement Network (FinCEN) announced civil money penalties against CommunityBank of Texas, N.A. (CBOT) for violating Bank Secrecy Act (BSA) and Anti Money Laundering (AML) regulations. FinCEN assessed a civil money penalty of $8 million and the OCC assessed a civil money penalty of $1 million.

CBOT failed to adopt and implement a BSA/AML system of internal controls to assure ongoing compliance with the regulations. This resulted in CBOT’s failure to timely file hundreds of complete suspicious activity reports (SARs) for approximately $100 million of suspicious activity. The suspicious activity involved illegal financial activity by its customers and processed by, at or through the bank even after it became aware certain customers were subjects of criminal investigations. The violations occurred between 2015 to 2019 and involved transactions connected to tax evasion, illegal gambling, money laundering and other financial crimes.

If your institution needs help with its BSA and AML programs, contact Doeren Mayhew’s regulatory compliance specialists.