Topics In This Issue

• Federal Issues

• Courts

• Miscellany

• Firm News

• Firm Publications

• Banking

• Consumer Finance

• Litigation

• Privacy/Data Security

Excerpt from "Banking"

Government Fines Bank $10.9 Million for BSA and AML Violations. On August 22, the Federal Deposit Insurance Corporation (FDIC), the Financial Crimes Enforcement Network (FinCEN), and the State of Florida Office of Financial Regulation (OFR) announced the assessment of $10.9 million in civil money penalties against a Florida bank for failure to implement an effective Compliance Program under the Bank Secrecy Act (BSA) and federal and state anti-money laundering laws. The FDIC, FinCEN, and OFR determined that the bank failed to implement internal controls to timely detect money laundering and other suspicious activity and failed to provide adequate staffing to ensure BSA compliance. The bank consented to the payment without admitting or denying the allegations.

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