On 12/16/21, FinCEN and the OCC announced on separate issuances that they assessed a total of $8 million civil money penalty on CommunityBank of Texas, N.A. (CBOT) for willful violations of the Bank Secrecy Act (BSA) and its implementing regulations. As a result of its own investigation, the OCC assessed a civil penalty of $1 million for related violations while FinCEN agreed with CBOT to a settlement of $7 million.
According to FinCENs release, CBOT admitted that it willfully failed to implement and maintain an effective AML program and that it willfully failed to report hundreds of suspicious transactions to FinCEN involving illegal financial activity by its customers processed by, at, or through the bank even after the bank became aware that certain customers were subjects of criminal investigations. The violations occurred from at least 2015 through 2019 and caused approximately $100 million in suspicious transactions to go unreported to FinCEN in a timely and accurate manner.
Read FinCEN’s full release here.
Read OCC’s full release here.