News & Analysis as of

Office of the Comptroller of the Currency Bank Secrecy Act Civil Monetary Penalty

Sheppard Mullin Richter & Hampton LLP

OCC and FinCEN Issue $200 Million in Penalties for BSA-AML Violations

On March 17, the OCC and FinCEN issued civil monetary penalties against a federal savings bank for “willfully” failing to meet minimum compliance program requirements and shoddy suspicious transaction reporting. The consent...more

Sheppard Mullin Richter & Hampton LLP

OCC and FinCEN Issue $9 Million in Penalties for BSA-AML Violations

On December 16, 2021, the Office of the Comptroller of the Currency (“OCC”) and the Financial Crimes Enforcement Network (“FinCEN”) issued civil monetary penalties against a Texas community bank for violations of the Bank...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Enforcement Action Highlights AML Compliance Program Failures and Conflicts of Interest for High-Risk MSB Customers

On February 27, 2017, FinCEN announced a $7 million civil monetary penalty against Merchants for willful violations of the BSA. Additionally, the Office of the Comptroller of the Currency (OCC), Merchants’ federal functional...more

WilmerHale

OCC Revises CMP Policy

WilmerHale on

For the first time in over twenty years, the Office of the Comptroller of the Currency (OCC) has formally changed its policy governing civil money penalties (CMP) against national banks, federal savings associations, federal...more

Goodwin

OCC and FinCEN Take Enforcement Actions and Assess Civil Money Penalty Against Small Bank for BSA/AML Violations

Goodwin on

The OCC entered into a consent order with a small, New Jersey-based bank with approximately $118 million in total assets for violations of the Bank Secrecy Act (the “BSA”). The OCC assessed a civil money penalty (“CMP”)...more

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