FDIC Fines BSA Officer for Misrepresentation

  • Source: fdic.gov

Treliant Takeaway:

Treliant helps firms to ensure they have sustainable and compliant BSA/AML and Economic Sanctions/OFAC compliance programs. Treliant’s team includes experienced industry leaders and subject matter experts such as former compliance officers, audit professionals, regulatory and supervisory examiners, as well as data and technology professionals. We understand how to make BSA/AML and Economic Sanctions/OFAC compliance programs work and can assist with program updates so that firms can stay current with changing regulatory expectations.

Order Highlights:

The FDIC determined that the BSA officer of a bank in Los Angeles, CA, while serving as First Vice President and BSA Officer, misrepresented to bank management and the FDIC the status of the bank’s Enhanced Due Diligence (EDD) reviews resulting in a large backlog of unfinished EDD reviews and failure to timely file Suspicious Activity Reports (SAR), by backdating some of the EDD reviews provided to FDIC examiners, and by deleting a bank analyst’s recommendation that a SAR be filed.  The BSA officer was assessed a $10,000 civil money penalty and is prohibited from seeking or accepting indemnification from any insured depository institution for the civil money penalty.

 

Author

Ross Marrazzo

Ross Marrazzo is Managing Partner of Treliant. He is also responsible for the firm’s Corporate & Regulatory Compliance and Global Financial Crimes Compliance services areas. Ross has over 34 years of domestic and international experience in the design, oversight, and assessment of corporate and regulatory compliance, Anti-Money Laundering/Bank Secrecy Act,…