CONSENT ORDER PROVIDES WINDOW IN REGULATORS' CONCERNS

The recently released Consent Order* filed by the OCC against Saddle River Valley Bank, of New Jersey, affords compliance officers valuable insight into what some regulators deem important in BSA/AML compliance.

(1) The bank may not initiate any international wire transfers until it has an "automated system for the processing of wires that will enable the bank to identify potentially suspicious activities, and monitor and aggregate transactions by originator and beneficiary."

(2) There cannot be any further Remote Deposit Captures**until the "bank has implemented risk management systems, written policies and procedures, and a BSA/AML programme ... that will result in due diligence on the bank's customers, their lines of business the parties to whom their customers are providing services through the bank, and those customers' lines of business, and the effective monitoring, detection, and reporting of suspicious accounts, in the processing of RDC transactions."

(3)A Look-Back Report, which appears to focus on previous international correspondent banking relationships.
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*Consent Order
http://occ.gov/static/enforcement-actions/ea2011-153.pdf
** The bank customer scans in an electronic image of cheques which he or she wishes to deposit, and then transmits them to the bank.