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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