Violations of the Requirement to Implement an Anti-Money Laundering Program
The Financial Crimes Enforcement Network has determined that Doha New York violated the requirement to establish and implement a reasonably designed anti-money laundering program. Since April 24, 2002, the Bank Secrecy Act and its implementing
regulations have required financial institutions to establish and implement anti-money laundering programs.3 A Federal branch of a foreign bank must implement an anti-money laundering program that conforms with the rules of the OCe. Since 1987, the OCC has required a program “reasonably designed to assure and monitor compliance” with reporting and record keeping requirements under the Bank Secrecy Act.4 Reporting re~uirements under the Bank Secrecy Act include the requirement to report suspicious transactions. An anti-money laundering program must contain the following elements: (1) a system of internal controls to assure ongoing compliance; (2) independent testing for compliance; (3) the designation of an individual, or individuals, to coordinate and monitor day-to-day compliance; and (4) training of appropriate personne1.6 The Branch failed to implement an adequate system of internal controls to ensure compliance with the Bank Secrecy Act and manage the risk of money laundering or other suspicious activity, or to conduct adequate independent testing to allow for the timely identification and correction of Bank Secrecy Act compliance deficiencies.
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IV.CIVIL MONEY PENALTY
Under the authority of the Bank Secrecy Act and the regulations issued pursuant to that Act,13the Financial Crimes Enforcement Network has determined that a civil money penalty is due for violations of the Bank Secrecy Act and the regulations implementing that Act, as described in this ASSESSMENT.Based on the seriousness of the violations at issue in this matter, and the financial
resources available to Doha New York, the Financial Crimes Enforcement Network has determined that the appropriate penalty in this matter is $5,000,000.
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Detailed assessment report link: here