ARLINGTON, Va. — The banks that have received a lot of media attention for Bank Secrecy Act violations had a lot of common problems, Charlotte Bahin, partner with Lord, Bissell & Brook LLP, shared with attendees of the Credit Union Times/EEI BSA conference today.
The most common problems for the banks that have been hit with the multi-million dollar fines included management review and board oversight. Board and upper management buy-in is key for top-down compliance. "The important thing is you have to have a process and follow that process and make sure your staff is doing that as well," she explained.
Other problems that were similar between Riggs Bank and ABN AMRO and some of the others who have been publicly fined are inadequate internal audit and noncompliance with the Office of Foreign Assets Control.
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