Jun 01 2009 Brett Wolf
The Federal Deposit Insurance Corporation has issued a cease-and-desist order to a Colorado-based bank operating with alleged anti-money laundering deficiencies. Rocky Mountain Bank and Trust's Bank Secrecy Act compliance failures included weak customer identification and suspicious activity reporting regimes, according to the FDIC.
The FDIC order requires RMBT to perform a "comprehensive" BSA risk assessment to determine "the vulnerability of its banking operations to attempts to launder money, finance terrorism, or conduct other criminal activities." This assessment must be completed by either "qualified" bank personnel or an independent consultant.
The order also obliges the bank to bolster its CIP regime "to ensure and maintain full compliance with the BSA and its implementing regulations, taking into consideration its size and risk profile."
As part of this process, RMBT must develop written procedures that outline its "procedures for utilizing third parties to assist in compliance with the CIP." These written procedures must include a description of "how the bank will monitor and verify that the third party is in compliance with bank policies."
The FDIC also ordered RMBT to beef-up its internal controls. The order requires that the bank adopt "adequate methods for conducting enhanced due diligence on high-risk accounts and customers at account opening and on an ongoing basis." It also requires the bank to strengthen its suspicious activity reporting regime.