Associated Bank, N.A.
Fine Amount:
$500,000
Penalty Type:
Issued by:
Total Assets $24.5 B (3/31/2014)
Associated Bank, N.A., Green Bay, Wisconsin, is a federally-chartered commercial bank with 247 offices located in Illinois, Minnesota, Virginia and Wisconsin. The OCC identified BSA/AML deficiencies that occurred primarily during 2010-2012, and issued a Consent Order on February 23, 2012, which in part required the bank to undertake remedial actions with respect to its BSA/AML compliance program. The Consent Order was terminated on March 11, 2014. The OCC on June 26, 2014, issued a Consent Order for a $500,000 civil money penalty in connection with the 2010-2012 deficiencies, which were described in the Order as follows:
a. the Bank failed to (i) conduct adequate risk assessments, (ii) conduct sufficient customer due diligence, (iii) properly identify high-risk customers, and (iv) implement an adequate suspicious activity monitoring system;
b. the Bank's independent testing of the Bank's BSA/AML compliance program was inadequate;
c. the Bank's BSA officer and staff lacked the necessary resources and expertise, including knowledge of regulatory requirements;
d. the Bank's BSA training efforts for staff were inadequate; and
e. after conducting a lookback, the Bank filed 670 new Suspicious Activity Reports.
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