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.
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