The consent order issued by the Office of the Comptroller of the Currency against USAA Bank imparts lessons for compliance officers in the financial services industry on how—and how not—to maintain a Bank Secrecy Act/anti-money laundering compliance program.
Internal Controls
Advice for navigating ‘fast and furious’ Russian sanctions landscape
To help sort through the gray area of evolving sanctions and export control restrictions against Russia, chief compliance officers should consider a handful of key best practices.
USAA fined $140M for AML compliance failures
USAA Federal Savings Bank must pay $140 million as part of consent orders reached with the Financial Crimes Enforcement Network and Office of the Comptroller of the Currency for its failures maintaining its Bank Secrecy Act/anti-money laundering compliance program.
MoneyGram, NYDFS agree on $8.25M settlement for supervision lapses
MoneyGram will pay $8.25 million as part of a settlement with the New York State Department of Financial Services for supervision failures regarding local agents processing suspicious transactions in China.
Nomination deadline closed for 2022 ‘Excellence in Compliance Awards’
The nomination deadline for CW’s third annual “Excellence in Compliance Awards” closed March 15. Winners will be announced in May.
Learning points from HSBC’s fine for AML failings
Significant investment in systems has not been fully effective in mitigating financial crime risk. A fine of nearly £64 million (then-U.S. $84 million) imposed on HSBC by the U.K. Financial Conduct Authority in December is a particularly potent example.
Deutsche Bank monitorship extended after breach of DPA
Deutsche Bank disclosed the Department of Justice determined it breached its obligations under a 2021 deferred prosecution agreement. As a result, the term of an independent compliance monitor at the bank has been extended until February 2023.
Top 10 reasons to attend Compliance Week 2022
A keynote with two SEC commissioners; interactive sessions on global sanctions, ESG, and ethical leadership; and a new conference location and format highlight Dave Lefort’s list of reasons to be excited for CW’s first in-person event in nearly three years.
MTS compliance monitorship extended one year
The Department of Justice and Mobile TeleSystems jointly agreed to voluntarily extend for one year the term of the Russian telecommunications company’s independent compliance monitorship in accordance with a 2019 deferred prosecution agreement.
Citi chief compliance officer to step down; search for new CCO launched
Citi Chief Compliance Officer Mary McNiff will step down and accept another post within the bank as part of a reshuffling of leadership to comply with orders issued in 2020 by the Office of the Comptroller of the Currency and Federal Reserve.


