Compliance Blog

Nov 24, 2009

A Little of This, A Little of That

Posted by Anthony Demangone

Here are a few things that have been rattling around my in-box recently.

  • A criminal BSA prosecution against a bank. You don't see this very often.  Someone asks me every so often what has to happen for the government to use this power under the Bank Secrecy Act.  This is a good example. This could be a good item to share in a training session to underscore that criminal prosecution is a real possibility.  However, it is usually used against an organization or official who uses their position to inentially evade the Bank Secrecy Act's requirements.  Here's a taste of what the bank allegedly did:

It was further part of the conspiracy that (the bank) opened multiple accounts held in the names of nominees or other business entities so that the cash deposits, on any one day in excess of $10,000, could be deposited into the various accounts, in order to conceal the relationship between the transactions and the depositors and to avoid the filing of any reports. Emphasis added.