Tuesday, October 22, 2013


A major Miami-area executive search firm was advertising recently for clerical staff, to prepare and file delinquent Suspicious Activity Reports for a bank, located here, that has a long and sordid history of AML compliance deficiencies. The employment offer was for an extremely small hourly wage, which means that anyone who was qualified, through training and experience, to analyze the available information, and properly compose SARs, would not be applying for the job. The bank officer who tried to cut corners by paying a pittance for this important compliance work should be terminated, in my humble opinion. 

Moreover, the bank was, according to the executive recruiter, more than ONE YEAR BEHIND in its SAR filings. Where are the Federal auditors and regulators here ? No bank, even one with a robust AML/CFT program, should be late filing its SARs the next year. The money launderers will be in, and out, of the bank, and long gone, well before the SARs are prepared and filed.

Apparently there are several other Miami banks with this same SAR delinquency. This is what happens when regulatory agencies only give offending banks repeated Cease & Desist Orders, when they catch them with violations. The banks simply do not fear the regulators. Only when one of the most egregious violator loses its charter will the other banks institute truly effective AML/CFT compliance. 

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