Old National Bank

Old National Bank is a Federally chartered bank headquarterd in Evansville, Indiana, with 200 domestic locations in 5 states in Illinois, Indiana, Kentucky, Michigan and Ohio. On January 14, 2014, the Comptroller issued a Consent Order for a Civil Money Penalty of $500,000.

BSA/AML deficiencies were addressed in a Consent Order issued by the OCC on June 4, 2012, which in part required the bank to undertake remedial actions with respect to its BSA/AML program. In the 1/14/14 CMP Order, the OCC cited findings that

• the bank failed to (1) conduct adequate risk assessments, (2) obtain more than the minimum information required for CIP purposes, (3) implement an adequate suspicious activity monitoring system, and (4) property identify high-risk customers.
• the bank's internal audit review failed to identify the deficiencies in the program
• the bank's BSA officer and staff lacked the necessary resources and expertise, including knowledge of regulatory requirements, and
• after conducting a lookback, the bank filed 110 new SARs and 172 supplemental SARs.