FinCEN’s New Elite Enforcement Division Assesses First BSA/AML Penalty, and It’s Big
The $37.5 million penalty to TD Bank is on top of the $600 million paid in restitution and the $15 million in SEC Fines. The latest penalty focuses on BSA/AML issues associated with failures to heed alerts and file Suspicious Activity Reports (SARs) related to the $1.2 billion Ponzi scheme by Scott Rothstein. The fine is first civil money penalty assessed by FinCEN’s new elite Enforcement Division "who target the exploitation of the financial system by illicit actors" focusing on "compromised financial institutions and their officers, managers, and employees; compromised jurisdictions; and third party money launderers who facilitate financial crime." [9/24]