$1.25 Million FDIC CMP for Alleged BSA Violations

A New York bank has entered into a Consent Order with the FDIC to pay a $1.25 million civil money penalty over allegations the bank violated the Bank Secrecy Act and its implementing regulations.  Notably, the same bank was subject to a NY DFS Consent Order in June 2015 following a joint safety and soundness examination with the FDIC.  That 2015 Order cited the bank for noncompliance with the BSA and other regulations and directed the bank to engage in extensive measures to enhance and improve BSA compliance including 1) risk assessment for potential BSA violations, 2) internal controls for monitoring, detecting, and reporting suspicious activity, and 3) employee training and independent testing.  The current Consent Order covers conduct both before and after the 2015 Order.