National Bank of Pakistan Required to Pay Civil Money Penalty for BSA/AML Violations

The Federal Reserve Bank of New York (Federal Reserve) and the New York Department of Financial Services (NYDFS) (collectively referred to as government parties) recently filed separate enforcement actions against the National Bank of Pakistan (bank). The National Bank of Pakistan is a multinational commercial bank incorporated in Pakistan, with the Pakistani government owning the majority of the bank. The bank holds more than $20 billion in assets and operates a foreign branch in New York. The bank allegedly violated the Bank Secrecy Act (BSA), anti-money laundering (AML) provisions, and the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) screening programs. The bank is required to pay the NYDFS $35 million dollars and the Federal Reserve $20.4 million in civil money penalties.