An OCC examiner assigned to your Bank repeatedly warned USB officials, such as the AMLO, of this impropriety of handling the Bank’s monitoring programs on the basis of the size of its staff as well as other resources. Realizing that the OCC would find USB’s resource-driven alert restrictions to be incorrect, Bank officials, like the CCO, intentionally concealed these techniques through the OCC. As an example, a Bank employee deliberately excluded recommendations to site restrictions through the moments of an internal Bank conference for fear that the OCC would disapprove regarding the Bank’s methods, plus in purchase to safeguard himself and their supervisor from undesirable consequences. Certainly, the AMLO described USB’s AML system to some other senior supervisor as a work to make use of “smoke and mirrors” to “pull the wool throughout the eyes” associated with the OCC.
USB additionally didn’t monitor Western Union (“WU”) deals involving non-customers associated with the Bank that occurred at Bank branches. The Bank processed WU transactions involving non-customers despite the fact that they might never be susceptible to the Bank’s deal systems that are monitoring. Even though Bank workers flagged particular transactions that are non-customer AML-related issues, the deals went uninvestigated. It had been maybe maybe perhaps not until July 1, 2014, that the lender applied a policy that is new prohibited WU transactions by non-customers.
For the duration of this research, the lender analyzed the effect of the lacking monitoring methods. The Bank’s analysis resulted in the generation of an additional 24,179 alerts and the filing of 2,121 SARs for just the six months prior to taking steps to remedy the practices. Читать далее →