Tag Archives: fin cen

Texas Bank Penalized $2 Million for Violations of Anti-Money Laundering

FinCEN assesses civil money penalty against Lone Star National Bank (Lone Star) of Pharr, Texas for willfully violating the Bank Secrecy Act

By Jeff Sorg, OnlineEd Blog

(November 2, 2017)

canstockphoto18625424 compliance street sign(WASHINGTON, D.C.) – The Financial Crimes Enforcement Network (FinCEN) today announced the assessment of a $2 million civil money penalty against Lone Star National Bank (Lone Star) of Pharr, Texas for willfully violating the Bank Secrecy Act (BSA). The action underscores the dangers that institutions face when taking on international correspondence activities without properly equipping themselves to manage such business. As noted in FinCEN’s assessment, among other lapses, Lone Star failed to comply with section 312 of the USA PATRIOT Act, which imposes specific due diligence obligations with respect to correspondent banking.

Many of the lapses in Lone Star’s BSA compliance were previously covered in an earlier action by the Office of the Comptroller of the Currency (OCC), but FinCEN’s action focusing on the bank’s 312 violations specifically highlights the need for a financial institution to avoid taking on international business for which it is not prepared. Lone Star’s Mexican financial institution customer was moving millions of dollars through Lone Star in a manner inconsistent with the parameters of a relationship which, at the outset, required greater scrutiny. Lone Star failed to identify and consider public information about the foreign bank owner’s alleged involvement in securities fraud. It also failed to verify the accuracy of assertions by the foreign bank with respect to source of funds, purpose of the account, and expected activity.

“Lone Star plainly failed to ask obvious due diligence questions in connection with its foreign bank account relationship, and did not follow up on inconsistencies in answers to the questions that it did ask,” said FinCEN Acting Director Jamal El-Hindi. “Notwithstanding the fact that the OCC already fined the bank, FinCEN’s assessment takes into account the penalties specifically applicable under FinCEN’s Section 312 authority. Smaller banks, just like the bigger ones, need to fully understand and follow the 312 due diligence requirements if they open up accounts for foreign banks. The risks can indeed be managed, but not if they are ignored.”

With respect to many of the deficiencies noted in FinCEN’s assessment, the OCC entered into a Consent Order and a Memorandum of Understanding with Lone Star in 2012. Lone Star continued to have severe programmatic anti-money laundering (AML) deficiencies through 2012, 2013, and 2014. As a result, in 2015, the OCC issued a Consent Order for a Civil Money Penalty in the amount of $1 million against Lone Star. Lone Star’s previous penalty payment to the OCC will be credited to FinCEN’s assessment and the bank will pay an additional $1 million to satisfy its obligation to FinCEN.

FinCEN recognizes that Lone Star has expended considerable resources to respond to the findings regarding its BSA program and to promote compliance with the OCC’s Consent Order. Lone Star is no longer engaging in the correspondent banking activities for which it was ill prepared. The bank has contracted outside consultants to conduct independent testing, conduct customer due diligence and suspicious activity lookbacks, and has expanded its BSA compliance organization.


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How to Comply with Anti-Money Laundering Training Requirements

(OnlineEd®, InlineEd) – Residential mortgage lenders take note: The August 13, 2012 deadline for compliance with the new anti-money laundering (AML) and suspicious activity report (SAR) final rule is fast approaching.

In A Nutshell

This new expanded regulation applies to every single non-bank mortgage brokerage and mortgage lending company, regardless of size. The mandatory compliance deadline is August 13, 2012. By this date or sooner, you must:

  • Perform an AML risk assessment
  • Implement a written AML Program, including policies and procedures
  • Train employees on AML
  • Develop training program for ongoing AML training and tracking of new employees
  • Conduct and keep records of annual AML training

Would you like an all-in-one solution for this? Would you like it right now? OnlineEd® has developed InlineEd to meet your compliance needs!

“Instant-AML” Training

The instant-solution to your Anti-Money Laundering training needs is called InlineEd. The InlineEd AML Compliance Bundle is a 100% web-based solution comes with AML training, complete record keeping and reporting abilities, and has no installation or IT integration requirements. Just sign up and you’ve got this issue solved!

How It Works:

  1. Submit your information and payment through the checkout page.
  2. Send us a list of all of your employees.
  3. We upload your list and give you back login information that you can issue to employees.
  4. You also receive a pre-made Anti-Money Laundering “policy template” which you can customize and use as your company’s own policy if you don’t already have one.

Each employee will then have personal access to the AML training online. Employees can log in and complete the training at their convenience. When the training is completed, their records are recorded in the online database. You can pull up these records at any time in real time.

You can use InlineEd to train your current employees and keep using the system for future employees. Just enter their information into the system when they are hired and the AML requirements will automatically be applied.

Room To Grow With InlineEd

InlineEd handles policies, procedures, training, tracking, report, records, and compliance.

InlineEd can also help you with many other compliance needs:

  • Company and compliance training
  • NMLS continuing education
  • Education tracking, records, and reporting
  • Policies & procedures

Take A Tour!


InlineEd(TM) is a software system developed by  OnlineEd® for mortgage broker and real estate lender continuing education and national compliance courses, as well as course compliance tracking software for employers.

For more information about InlineEd, please contact Paul Cleary at OnlineEd: (866) 519-9597 or visit www.onlineed.com/inlineed