Bank Hit With $15 Million Penalty for ‘Willful’ BSA Violations

WASHINGTON—The Financial Crimes Enforcement Network (FinCEN) has assessed a $15-million civil money penalty against Shinhan Bank America (SHBA) for “willful” violations of the Bank Secrecy Act (BSA) and its implementing regulations.

“SHBA willfully disregarded its obligations under the BSA to maintain an effective anti-money laundering (AML) program and to identify and report suspicious transactions to FinCEN, despite being informed of its deficiencies as far back as 2015,” said FinCEN’s Director Andrea Gacki.  “(The) action should serve as a reminder to banks of all sizes that AML program deficiencies must be promptly and effectively addressed, and that FinCEN takes seriously repeated failures to remediate violations of the BSA.”

‘Willful Violations’

According to FinCEN, SHBA admitted to willfully violating the BSA from April 2016 through March 2021, by failing to implement and maintain an effective AML program that was reasonably designed to guard against money laundering and failing to timely report several hundred transactions to FinCEN involving suspicious financial activity by its customers processed by, at, or through the bank.  

As a result, FinCEN said tens of millions of dollars in suspicious transactions were not reported to FinCEN in a timely manner, including transactions connected to tax evasion, public corruption, money laundering, and other financial crimes.

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