A deep dive into the consent order issued last week by the Office of the Comptroller of the Currency (OCC) against USAA Federal Savings 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 (BSA/AML) compliance program.
On March 17, USAA Bank agreed to pay $140 million as part of two separate consent orders reached with the OCC and the Financial Crimes Enforcement Network for the bank’s “willful” failure to implement and maintain a BSA/AML compliance program. The OCC also issued a cease-and-desist order against the bank, which requires it “to take broad and comprehensive corrective actions to improve internal controls, training, staffing, and third-party risk management of its BSA/AML program,” the agency stated.
