TCF Bank*, an American financial institutions, with 430 branches located in Minnesota, Illinois, Minnesota Michigan, Indiana, Arizona, and South Dakota, has agreed with the OCC, to a $10m fine, for BSA deficiencies, primarily for SAR violations. The bank, which had a prior Cease & Desist in July 2010, had late-filed over 2300 SARS, with a total value of $70m.
The OCC agreement specifically noted the following deficiencies:
(1) Cash transactions indicative of Structuring.
(2) Wire transfers, where both the Source of Funds, and the purpose of the transactions, were unknown.
(3) Thirteen SARs improperly filed, where there were questions of terrorist financing.
(4) Transactions that appeared to represent unusual activity.
Readers who wish to review the entire text can find it on the OCC website here.