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From Banking and Finance Law Daily, October 23, 2018

Capital One fined $100 million for anti-money laundering deficiencies

By Andrew A. Turner, J.D.

The Office of the Comptroller of the Currency has assessed a $100 million civil money penalty against Capital One, N.A. for failing to comply with a 2015 consent order requiring the bank to remedy deficiencies in its anti-money laundering program. According to a new consent order, the bank failed to file required Suspicious Activity Reports and initiated wire transfer transactions which contained inadequate or incomplete information since the issuance of the earlier consent order.

The 2015 cease and desist order found the bank:

  • lacked an enterprise-wide Bank Secrecy Act/Anti-Money Laundering (BSA/AML) risk assessment;
  • had systemic deficiencies in its transaction monitoring systems, risk management, and quality assurance programs for its remote deposit capture services;
  • had systemic deficiencies in its customer due diligence processes and failed to have customer due diligence and enhanced due diligence policies and processes specific to correspondent banking; and
  • lacked a process by which BSA/AML control decisions are escalated to Risk Management.

Companies: Capital One, N.A

MainStory: TopStory BankSecrecyAct EnforcementActions

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