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From Banking and Finance Law Daily, February 8, 2018

Rabobank agrees to $369 million in forfeiture, civil penalties for BSA/AML deficiencies

By Nicole D. Prysby, J.D.

On Feb. 7, 2018, the Office of the Comptroller of the Currency announced a $50 million penalty against Rabobank, N.A. of Roseville, California, for deficiencies in the bank’s Bank Secrecy Act and anti-money laundering compliance program. The Department of Justice also issued a statement about the proceedings, explaining that Rabobank would pay approximately $369 million in total, for forfeiture and civil money penalties and fines. The DOJ statement also noted that Rabobank pleaded guilty to conspiracy to defraud the U.S. by obstructing a bank examination. Rabobank’s deficient BSA/AML compliance program allowed hundreds of millions of dollars in untraceable cash to be deposited to its branches, without proper notification to federal regulators. Rabobank also attempted to conceal the deficiencies in its compliance program during a 2012 examination.

A Dec. 5, 2013, Consent Order identified deficiencies in Rabobank’s BSA/AML compliance and required the bank to submit and implement a comprehensive BSA/AML action plan and risk assessment. It also required that Rabobank engage an independent consultant to review transaction and account activity for 2010-2013.

The Feb. 6, 2018, Consent Order for the civil money penalty states that, since 2012, the bank failed to perform adequate customer due diligence and enhanced due diligence processes, as required by the BSA, failed to adequately investigate questionable activity, and failed to cooperate with an OCC examination in 2012. The independent consultant engaged under the terms of the 2013 Consent Order found 472 Suspicious Activity Reports for the 2010-2013 period, approximately $233 million in previously unreported suspicious activity. In the Feb. 5, 2018, Plea Agreement, Rabobank pleaded guilty to one count of felony conspiracy.

Rabobank issued a brief press release, stating that it had settled the compliance program issues and that it was released from the 2013 Consent Order.

The OCC also issued an order terminating the 2013 Consent Order, as all corrective action from that order has been implemented.

Companies: Rabobank, N.A.

MainStory: TopStory BankSecrecyAct CrimesOffenses DirectorsOfficersEmployers EnforcementActions

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