In 2018, the Financial Crimes Enforcement Network (FinCEN) assessed a civil money penalty against U.S. Bank for its failure to have an effective anti-money laundering (AML) program, to file suspicious activity reports (SARs) and to adequately report currency transaction reports (CTRs). In a related action filed in March 2020, FinCEN assessed a civil money penalty against Michael LaFontaine, former Chief Operational Risk Officer at U.S. Bank, for his role in the failure to prevent U.S. Bank’s violations of the Bank Secrecy Act (BSA) and relevant implementing regulations.
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