Ethereum

95

Collection

The Banksters-old

Description

The Comptroller finds, and the Branch neither admits nor denies, the following: (1) The Branch violated 12 C.F.R. § 21.21 and 12 C.F.R. § 21.11. Specifically, the Branch failed to adopt and implement a compliance program that adequately covered the required BSA/AML program elements, and the requirements of OFAC, and the Branch failed to timely file Suspicious Activity Reports (“SARs”) related to suspicious customer activity. (2) Some of the critical deficiencies in the elements of the Branch’s BSA/AML compliance program that resulted in a violation of 12 C.F.R. § 21.21, included the following: • The Branch had an inadequate system of internal controls, ineffective independent testing, a weak BSA Officer function, and insufficient training. • The Branch had systemic deficiencies in its transaction monitoring systems, which resulted in monitoring gaps. These systemic deficiencies resulted in alert and investigation backlogs, and led to a failure to file SARs in a timely manner. 3 • The Branch had systemic deficiencies in its customer due diligence (“CDD”), enhanced due diligence (“EDD”), and customer risk rating processes. (3) The Branch failed to file the necessary SARs concerning suspicious customer activity in a timely manner, in violation of 12 C.F.R. § 21.11.

Traits

Year

2018

Agency

Office of the Comptroller of the Currency

Company

Bank of China