Federal Reserve Board Requires AML Enhancements Prior To Bank Merger

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On June 18, the Federal Reserve Board announced the execution of a written agreement with a bank and its bank and non-bank subsidiaries to resolve alleged shortcomings in the institutions’ BSA/AML compliance programs. The bank previously announced that its planned merger with another institution was delayed due to the Federal Reserve Board’s concerns. The bank retained a consultant to assist with compliance enhancements, which under the written agreement include, among other things: (i) a revised firm-wide written BSA/AML compliance program, (ii) a revised written customer due diligence program, (iii) a written suspicious activity monitoring and reporting program, and (iv) a six month suspicious activity look-back review.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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