
Being a Smaller Bank Is Not a Defense for AML Due Diligence Failures
FinCEN assessed this Texas bank a $2 million penalty, even though the OCC had already fined the bank, for "willfully violating" BSA by taking on international correspondence activity without properly equipping itself to manage such business. "Smaller banks, just like the bigger ones, need to fully understand and follow the 312 due diligence requirements if they open up accounts for foreign banks." [11/2/17]


