Capital One Bank, NA has entered into a Consent Order with the office of the Comptroller of the Currency (OCC), whereby the bank will pay a $100m Civil Money Penalty. The Order stipulates that the bank:
(1) Had an inadequate compliance program for required BSA/AML, by reason of an inadequate system of internal controls, and ineffective independent testing.
(2) Failed to file all necessary Suspicious Activity Reports (SARs).
(3) Has systemic deficiencies into transaction monitoring systems, risk management, and quality assurance programs, for its remote deposit capture services.
(4) Had defective customer due diligence and enhanced due diligence policies and processes, specific to correspondent banking.
Readers who wish to review the 9-page Consent Order may access the complete text here.