Compliance Blog

Earlier this month, the Comptroller of the Currency (OCC) issued this consent order against Eastern National Bank of Miami, Florida.  Now, you have to take another person's consent order with a grain of salt.  It is sort of like looking through someone else's medicine cabinet to determine what pills to take.  That being said, I always like to read consent orders or cease and desist orders to see other regulators are up to.

If you read the consent order linked above, you'll see quite a few things that Eastern National Bank must accomplish, sooner rather than later.  Here are some of the items:

• The BSA Officer or his/her designee shall periodically review, not less than each calendar year, all account documentation for all high risk accounts and the related accounts of those customers at the Bank to determine whether the account activity is consistent with the customer’s business and the stated purpose of the account.
• (Periodic) reports shall include reports on any type of subpoena received by the Bank and on any law enforcement inquiry directed to the Bank and any action taken by the Bank on the affected account.
• Within 90 days, the Bank must have documentation of the following information for all deposit account customers (those posing higher than normal risk):
  • any relevant financial information concerning the customer;
  • the type of business conducted by the customer;
  • the customer’s source of income or wealth. 

For BSA Officers, this consent order is a good read.