Every indexed document

lack of reporting capabilities over missing information

procedures and controls; provide adequate training; and perform periodic independent testing of its AML

seven MSBs were subject to enforcement actions primarily for failure to register

accurate or timely Suspicious Activity Reports (SARs)

designation of compliance officer/personnel

FinCEN assessed a $12 million CMP on Sigue Corporation for

thereby eliminating detection and review of potentially

FINRA assessed a $1 million penalty against E""Trade Securities and E""

the Bank is required to arrange for an independent look back for suspicious activity

and suspicious activity reporting related to that monitoring. These fìndings

the independent BSA and the anti-money laundering audit function

the OCC issued a Cease and Desist Order against Citibank

HSBC was the subject of a hearing held by the Senate

even when a customeis association with PEPs could

which caused the bank to file many late SARs; and failure to appropriately designate

inhibiting its assessment of customer risk and the identification of suspicious activity in

' resulting in limited and ineffective BSA/AML monitoring

as required by applicable suspicious activity reporting laws and

for violating the Bank Secrecy Act and its underlying regulations.

the Office of the Comptroller of the Currency announced its issuance of a