Ryan W.’s Post

🚨 Enforcement Action Alert 🚨 The Office of the Comptroller of the Currency (#OCC) has taken decisive action against City National Bank by assessing a $65 million civil money penalty related to systemic deficiencies in the Bank’s risk management and internal controls. In doing so, the #OCC is mandating sweeping reforms to address deficiencies in compliance with the Bank Secrecy Act (#BSA), Anti-Money Laundering (#AML) protocols, operational risk management, and fair lending practices. 🔍 In response to the consent order, City National Bank is now obligated to form a compliance committee dedicated to ensuring adherence to the order's stringent requirements. 📝 The bank's extensive to-do list includes submitting a detailed action plan for compliance, overhauling policies to bolster operational risk and internal control frameworks, and enhancing measures to counter money laundering and terrorist financing risks. 🛡️ Crucial steps include revamping BSA/AML internal controls, adopt written BSA/AML and financial sanctions risk assessments, refining customer due diligence (#CDD) & #KYC processes, and revise policies and standards for the effective identification and mitigation of the risks associated with money laundering and terrorist financing. 🏦 The bank is also tasked with strengthening its staffing, internal audit programs, and submitting a revised strategic plan, ensuring a fortified and compliant operational structure. 📊 This consent order signifies a rigorous stance on maintaining the integrity of financial institutions, emphasizing the importance of robust compliance mechanisms and the role of corporate governance in safeguarding the financial system. Follow the Greater St. Louis ACAMS Chapter for regular updates on financial crimes news and regulatory updates! 🤝 #BankingCompliance #AML #BSA #RiskManagement #FinancialIntegrity #financialcrimescompliance #financialcrimes #financialcrimesprevention #enforcementaction https://lnkd.in/et3SrtRY https://lnkd.in/gpBqt3tM

The Financial Conduct Authority (#FCA) has encouraged #banks across the #UK to impose #cash deposit limits, in a bid to stop #money laundering.  #NatWest and #Barclays are limiting the amount of cash customers can deposit into their personal bank #accounts. #antimoneylaundering #AML #moneylaundering #dirtymoney #CFT #counterterrorismfinancing #financialcrime #financialcrimes #compliance #complianceofficer #duediligence #terroristfinancing #pep #sanctions #audit #FinancialIntelligenceUnits #FIU #SuspiciousActivityReport #cdd #kyc #regulations #CFP #risk #riskmanagement #investigation #monitoring #bank #unitedkingdom

APPLES TO APPLES? Office of the Comptroller of the Currency in the US has imposed a penalty of USD 65 mln on RBC's wholly-owned subsidiary, City National Bank as well as a C & D (Cease & Desist) order asking it to improve its compliance risk mgmt related to BSA/AML as well as ameliorating its strategic plan and fair lending. However, this does not involve any instances of money laundering; it is the strengthening of policies & procedures that are mainly at issue. What is a Cease & Desist Order?   Briefly, it is a final order that may be issued by OCC when a bank engages in an unsafe or unsound practice or violates a law, rule, regulation, condition imposed in writing. In addition to requiring a bank to cease & desist from the unsafe or unsound practice or violation and to take affirmative action to correct or remedy any conditions resulting from any violation or practice, a C&D order may require a bank to make restitution or provide reimbursement, restrict asset growth, dispose of a loan or other asset, rescind an agreement or contract, employ qualified officers or employees, or take other actions the OCC determines to be appropriate. A C&D order may also place limitations on a bank’s activities or function. For the fiscal year 2023, OCC had issued 4 bank C & D orders and imposed 3 bank CMPs (Civil Monetary Penalties) aggregating to USD 90 mln. There are numerous C & D conditions placed in OCC's consent order with regard to City National's BSA/AML internal controls, OFAC risk assessments, and CDD & KYC program & risk identification and will, inter-alia, entail a detailed & accurate documentation of personnel roles & responsibilities; application of appropriate thresholds in the bank's automated monitoring systems and their validation; procedures for SARS and CTRs preparation & a staffing assessment; design of risk assessment methodologies related to BSA/AML, OFAC, sanctions and other illicit financial activity risks; detailed analysis of all pertinent data obtained regarding the specific risk categories. Meanwhile, only a couple of months ago, RBC was fined a rather small amount of ~ CAD 7.5 mln by FINTRAC Canada | CANAFE Canada, for failing to provide information in the prescribed form in suspicious transactions reports, and not keeping written policies and procedures up to date. I am not too much aware of the governance structure & composition of City National Bank but I understand that Mr. Doug Guzman, group head of Wealth Management & Insurance at RBC, is still on City Nat'l board. Apparently, insofar as the AML/CFT program of City National, many items listed in the consent order when formally signed into an action plan, will occupy quite a bit of time of the boards, in addition to the integration plan of HSBC-Canada & RBC. I will be glad to assist RBC! Until later, Faisal Anwar, CCEP-I CFBR: Canadian Bankers Association, Bank of Canada, Md. Azam - MCS, CAMS, AMLA, Ahsan Habib, MBA, CAMS, FIS, Souzan Esmaili, ACAMS

OCC Releases Bank Supervision Operating Plan for Fiscal Year 2025 today. (quoted from their release) WASHINGTON—The Office of the Comptroller of the Currency (OCC) today released its bank supervision operating plan for fiscal year (FY) 2025. The plan outlines the OCC’s supervision priorities and objectives for the year. It also facilitates the implementation of supervisory strategies for individual national banks, federal savings associations, federal branches and agencies of foreign banking organizations, and third-party service providers subject to OCC examination. OCC staff uses this plan to guide its supervisory priorities, planning, and resource allocations . Key areas of heightened focus for supervisory strategies in FY 2025: - Financial - Credit - Allowance for credit losses - Asset and liability management - Capital - Climate-related financial risks for banks with over $100 billion in total consolidated assets - Operational - Cybersecurity - Enterprise change management - Operations - Third-party risks - Payments - Compliance - Bank Secrecy Act/anti-money laundering/countering the financing of terrorism and Office of Foreign Assets Control - Consumer compliance - Community Reinvestment Act - Fair lending The OCC provides periodic updates about supervisory priorities, emerging risks, and horizontal risk assessments in the Semiannual Risk Perspective in the fall and spring. Fiscal Year 2025 Bank Supervision Operating Plan (PDF) https://lnkd.in/gDU_KJye #operationalrisk #cybersecurity #compliance #BSAAML #climaterisk https://lnkd.in/g3C_RgCC

I had to defer the start of my lecture on operational risk for my Management of Financial Institutions class because I spent the time discussing TD Bank's recent penalties for weaknesses in its anti-money laundering (AML) framework (an operational risk example nonetheless). This is why my students think I am weird because I am most excited during a "crisis". I explain that I am really most excited when I can utilize real world recent cases in my courses, and we have not had one this big since Danske Bank. #moneylaundering #operationalrisk #enforcements

Government estimates reveal that between $43bn to $113bn is laundered every year in Canada. Recently, regulators uncovered significant weaknesses in Toronto-Dominion Bank’s #AML compliance controls which criminals can use as avenues to launder money.  Discover the key takeaways from this case, why TD Bank has been ordered to overhaul its #risk management controls, and how they are responding to tighten up against financial crime: https://bit.ly/3xxd0aa

The latest from the Globe and Mail's business commentary, by Rita Trichur: OSFI’s stop-and-go approach to anti-money laundering at banks is baffling. Its decision to reprioritize financial crime is muddying the waters about whether OSFI or FinTRAC will get the final say on bank compliance.

https://lnkd.in/epFR_3uT The OCC found that City National “engaged in unsafe or unsound practices” related to the management of operational risk, strategic risk, investment management practices and compliance, including practices related to the Bank Secrecy Act and anti-money laundering and fair lending rules. #Fines

The Federal Reserve, OCC, and FDIC recently released joint guidance intended for community banks. This guidance serves as a #TPRM resource, highlighting each step of managing #vendorrelationships, and much more. Read more from Banking Dive: https://hubs.ly/Q02wKkM50 #OCC #FDIC #thirdpartyrisk

Banks should never get comfortable with the idea that MRAs and MRIAs are simply the cost of doing business. When operational losses are egregiously "budgeted for", risk appetites become bigger than the bank can stomach. "Deficiencies in the bank’s BSA/AML program included those related to internal controls and risk management practices; risk assessments; customer due diligence; customer risk ratings; suspicious activity identification, evaluation, and reporting; governance; staffing; independent testing; and training, among others." https://lnkd.in/e33EWJ3W