TCF National Bank

On January 25, 2013, the OCC announced that it had issued a consent order for the assessment of a $10 million civil money penalty against TCF National Bank, with a home office in Sioux Falls, SD, and 436 total offices in Arizona, Colorado, Illinois, Indiana, Michigan, South Dakota, and Wisconsin.

The OCC had in July 2010 issued a consent C&D order (see below) for failure to establish and maintain an adequate BSA/AML program, citing SAR violations, and program violations.

Under the earlier Order, the bank had a consultant conduct a look-back to review activity specified in the Order from November 2008 through July 2010, which resulted in the bank's late-filing of 2,357 SARs covering transactions of about $70 million, involving structuring and other extraordinary customer transactions. In a November 2011 exam, the OCC identified 13 failures to properly file SARs on transactions possibly related to terrorist financing (the SARs had been filed, but were determined to be inadequate and "of poor quality." For example, the "terrorist financing" box on the SARs had not been checked (although the narrative made reference to possible terrorist financing), and in some cases, the narrative section was considered inadequate.