Toward the end of every week, Compliance Week puts a snarky spotlight on individuals, companies, and governments that “Failed It” in the areas of ethics and compliance during the week and gives out kudos to those that “Nailed It.” If we missed any or if you have any nominations for next week, let us know on Twitter (@ComplianceWeek) or in the comments section below.
Nailed It
Bank of America: One of the more interesting suspicious activity reports (SARs) unveiled as part of the blockbuster “FinCEN Files” reports that dropped this week was a curious case of one bank investigating another. The SAR was filed in 2016 by Bank of America (BoA) compliance officers regarding suspicious Russian and Baltic state transactions flowing through Deutsche Bank to BoA customers. BoA wanted answers about the source of the money, so it went directly to Deutsche Bank to find out. They were stonewalled at every turn, according to the SAR, with Deutsche Bank allegedly even turning away BoA officials who flew from New York to London to talk to a Deutsche Bank executive who sent them away without even a conversation. Kudos to BoA for taking it a step further than “observe and report” and doing a little probing of their own, even if they were ultimately unsuccessful. And it was certainly a bad look for the already troubled Deutsche Bank to turn away another bank looking for answers. —Dave Lefort
