The Laundry Man by Kenneth Rijock ( Penguin/Random House UK)

Friday, February 22, 2019


It would appear that M(itsubishi)UFG Bank Ltd*. cannot remedy the BSA/AML deficiencies in its compliance program, for again the Office of Comptroller of the Currency has imposed a Cease and Desist, captioned now as a Consent Order. We have seen prior C & D orders issued by US regulators, and the bank does not seem to be fixing its systemic defects.

Some of the many shortcomings detailed in the Consent Order:
(1) Failure to timely file SARs, Suspicious Activity Reports.
(2) Failure to implement effective compliance on correspondent accounts of foreign financial institutions.
(3) Failure to maintain and effective compliance program that covers BSA/AML.
(4) Systemic deficiencies in transaction monitoring systems.
(5) Gaps in trade finance monitoring.
(6)  Insufficient internal Audit functions.

Readers who wish to review the complete text of the 25-page Consent Order may access it here.

* The bank changed its name to MUFG Bank Ltd., which may be considered misleading, as the prior regulatory actions were against the bank under its original name. American businesses might not know that the bank, now without any indication that it is a foreign bank, has a history of regulatory black eyes.

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