US Bancorp was fined $613 million dollars for criminal violations of the Bank Secrecy Act. Specifically, the bank willfully failed in its anti-money laundering responsibilities. The bank imposed hard caps on the number of alerts that its transaction monitoring system could generate and understaffed AML/CFT roles.

US Bancorp appears to have sacrificed a robust AML/CFT regime in order to save some money on its compliance program. The idea of imposing hard caps on alerts may be appealing to banks (as these alerts require staff to validate, verify, and act), but undermines the integrity of a transaction monitoring system.

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Compliance, Money Laundering, Terrorist Financing


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