On April 5, 2012, the Office of the Comptroller of the Currency (“OCC”) issued a Cease and Desist Order (the “Order”) against Citibank, N.A. (“Citi”), Sioux Falls, South Dakota.

In summary, the Order requires Citi to take comprehensive corrective actions to improve its Bank Secrecy Act (“BSA”) Compliance Program. The OCC alleged to find deficiencies with respect to Citi’s:

  • Internal controls;
  • Customer due diligence;
  • The independent BSA and anti-money laundering audit function;
  • Monitoring of its remote deposit capture and international cash letter instrument processing in connection with foreign correspondent banking; and
  • Suspicious activity reporting related to that monitoring.

In addition, the Order requires Citi to conduct an independent review of account and transaction activities (“Look-Back”) covering areas to be specified in writing by the OCC. The purpose of the Look-Back is to determine whether suspicious activity was timely identified and reported by Citi.

Read the Cease and Desist Order.

This publication is for general information only. It is not legal advice, and legal counsel should be contacted before any action is taken that might be influenced by this publication.

Established in 1925, Gunster is one of Florida’s oldest and largest full-service law firms. The firm’s clients include international, national and local businesses, institutions, local governments and prominent individuals. Gunster maintains its presence in Florida with offices in Fort Lauderdale, Jacksonville, Miami, Palm Beach, Stuart, Tallahassee, Tampa, Vero Beach and West Palm Beach. Gunster is home to more than 165 attorneys and 200 committed support staff, providing counsel to clients through 18 practice groups including banking & financial services; business litigation; construction; corporate; environmental & land use; government affairs; health care; immigration; international; labor & employment; leisure & resorts; private wealth services; probate, trust & guardianship litigation; professional malpractice; real estate; securities and corporate governance; tax; and technology & entrepreneurial companies. Gunster is ranked among the National Law Journal’s list of the 250 largest law firms.


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