In case you missed it, the Financial Crimes Enforcement Network (FinCEN) announced it completed an investigation, which led to a consent order and a $140 million civil money penalty against USAA Federal Savings Bank (USAA) for violations of the Bank Secrecy Act (BSA) and its implementing regulations. This enforcement action can serve as an example of growing pains and the importance of updating the BSA/AML compliance program as membership and product types expand.
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